On August 26, 2013, in Waugh Chapel South, LLC v. UFCW (4th Cir. 2013), the U.S. Court of Appeals for the Fourth Circuit delivered a victory, in part, to employers and, in part, to labor. In its decision, the Fourth Circuit expanded the scope of activity subject to the secondary boycott proscriptions of the National Labor Relations Act (NLRA), but limited the type of organizations that are subject to those proscriptions.
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