In NLRB v. Interboro Contractors, Inc., 388 F.2d 495, 500 (2d Cir. 1967), the Court of Appeals for the Second Circuit stated that the efforts of an individual employee acting alone to enforce the provisions of a collective bargaining agreement may be deemed "concerted," and thus protected, at least when the individual's interpretation of the agreement has a reasonable basis.
In N.L.R.B. v. C I Air Conditioning, Inc., supra, 486 F.2d 977, 978, the court recognized the "emergence of [the Interboro] rule" but found it unnecessary to follow.
29 U.S.C. § 151 Cited 5,091 times 34 Legal Analyses
Finding that "protection by law of the right of employees to organize and bargain collectively safeguards commerce" and declaring a policy of "encouraging the practice and procedure of collective bargaining"