The U.S. Court of Appeals for the Fourth Circuit recently upheld an order
of the National Labor Relations Board ("Board"), finding that an
employer’s uneven enforcement of its business only e-mail policy
violated the National Labor Relations Act (NLRA). Media Gen.
Operations Inc., d/b/a Richmond Times-Dispatch v. NLRB, 4th Cir., No.
06-1023 (unpublished opinion 3/15/07).