# NLRB Division of Advice Memorandum, Case No. 18-CA-273796 (The Home Depot): The Home Depot (18-CA-273796)

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_18-CA-273796

## Section

- **Citation:** NLRB Division of Advice Memorandum, Case No. 18-CA-273796 (The Home Depot)
- **Heading:** The Home Depot (18-CA-273796)
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** NLRB Division of Advice Memoranda (rolling 10-year window) / The Home Depot (18-CA-273796)

## Text

United States Government
National Labor Relations Board
OFFICE OF THE GENERAL COUNSEL
Advice Memorandum
S.A.M.
DATE:
September 9, 2021
TO:
Jennifer Hadsall, Regional Director
Region 18
FROM:
Richard A. Bock, Associate General Counsel
Division of Advice
SUBJECT: The Home Depot
Case 18-CA-273796
506-2001-5000
506-4033-5500
506-6090-3200

The Region resubmitted this case for advice as to whether it should allege, as an
alternative to its primary argument that the Charging Party concertedly wore a Black
Lives Matter (BLM) slogan on his apron, that his conduct in wearing the slogan was
protected under the Board’s doctrine of “inherently concerted” activity. We conclude
that employee discussions in the workplace regarding racism should be deemed
inherently concerted because systemic racism, including an employer’s racial
discrimination or racial harassment, and/or tolerance of such discrimination or
harassment, necessarily implicates significant terms and condition of employment
and is of vital importance to employees. We further conclude that the Region should
urge the Board to expand the circumstances under which it applies the inherently
concerted doctrine beyond a conversation between two people to include the wearing
of a slogan or button. Thus, the Region should argue, in the alternative, that the
Charging Party’s individual wearing of the BLM slogan on his work apron was
inherently concerted.

BACKGROUND AND FACTS

This case was initially submitted for Advice concerning the scope of the notice-
posting remedy for the Employer’s unlawful application of its facially-lawful dress-
code policy to interfere with protected concerted activity, i.e., to prohibit an employee
from displaying a “Black Lives Matter” (BLM) slogan on his work apron, and its
subsequent discipline and constructive discharge of him for refusing to stop
displaying the slogan
r Advice concerning the scope of the notice-
posting remedy for the Employer’s unlawful application of its facially-lawful dress-
code policy to interfere with protected concerted activity, i.e., to prohibit an employee
from displaying a “Black Lives Matter” (BLM) slogan on his work apron, and its
subsequent discipline and constructive discharge of him for refusing to stop
displaying the slogan. In our initial Advice Memorandum in this case, we concluded
that a nationwide notice-posting is appropriate here in light of the Employer’s
admission that it consistently enforces its dress-code policy at all of its stores so as to
preclude all political messages, including the protected, concerted wearing of BLM
slogans in the workplace. We further concluded that the Region should urge the

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Board to revisit its recent decision in AT&T Mobility,1 return to its prior approach of
requiring rescission of rules that have been unlawfully applied to restrict Section 7
rights, and also, as suggested by Chairman McFerran in her partial dissent in AT&T
Mobility, condition reinstatement of the rule on the addition of a disclaimer that the
rule will not be applied to restrict Section 7 activity.2 Accordingly, the Region was
directed to seek an affirmative order requiring the Employer to rescind or revise its
unlawfully-applied dress code policy. And for the same reasons that a nationwide
notice-posting is appropriate, the Region was also directed to seek a nationwide
rescission remedy.

The Home Depot (the Employer) is a large home-improvement retailer with
approximately 500,000 employees and more than 2,200 stores in the U.S., Canada,
and Mexico. The Employer maintains company-wide apron and dress-code policies,
both of which provide, in relevant part:

The Home Depot apron is the brand of the Company. Customers identify us by it,
and it symbolizes our commitment to customer service
t (the Employer) is a large home-improvement retailer with
approximately 500,000 employees and more than 2,200 stores in the U.S., Canada,
and Mexico. The Employer maintains company-wide apron and dress-code policies,
both of which provide, in relevant part:

The Home Depot apron is the brand of the Company. Customers identify us by it,
and it symbolizes our commitment to customer service. To be most effective,
associates wearing an apron must present a consistent image to the public. While
The Home Depot respects the personal opinions and beliefs held by associates
and customers, the apron is not an appropriate place to promote or
display religious beliefs, causes or political messages unrelated to
workplace matters, or messages that would violate our policies on
discrimination and unlawful harassment…. (Emphasis added).

Since he began working for the Employer at one of its Minneapolis, Minnesota
stores (Store No. 2807) in August 2020, the Charging Party had been wearing a BLM
slogan prominently displayed in writing on his Home Depot apron. Throughout his
employment, and as recently as early February 2021, the Charging Party and a small
group of coworkers informed management of persistent racial harassment by a
coworker toward themselves, colleagues, and customers. In February 2021, Black
History Month posters were vandalized in the break rooms, prompting the Employer
to send its staff two e-mails addressing the issue and informing employees that such
actions would not be tolerated. After the first email from the Employer, the Charging
Party and a coworker spoke with management about the subject of the email needing
a group discussion
es, and customers. In February 2021, Black
History Month posters were vandalized in the break rooms, prompting the Employer
to send its staff two e-mails addressing the issue and informing employees that such
actions would not be tolerated. After the first email from the Employer, the Charging
Party and a coworker spoke with management about the subject of the email needing
a group discussion. In response to the second Employer email to staff, the Charging
Party responded by email back to the Employer regarding the vandalism, again
raising group concerns and urging the Employer to call a meeting for employees to
discuss the incidents, and stressing the importance of helping employees of color feel

1 AT&T Mobility, LLC., 370 NLRB No. 121, slip op. at 7 (May 3, 2021) (overruling
prong three of Lutheran Heritage Village–Livonia, 343 NLRB 646 (2004)).

2 See id., 370 NLRB No. 121, slip op. at 16 (Chairman McFerran, dissenting in part
and concurring in part).

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safe. The Employer met with the Charging Party shortly thereafter, informing him
that he was violating the dress code policy by having BLM written on his apron and
giving him the choice between wearing an apron without the slogan or quitting; the
Charging Party chose the latter, resigning his employment in mid-February 2021.

The Region found merit to a number of allegations in the instant charge,
including that the Employer: disciplined/suspended the Charging Party for engaging
in protected concerted activity, and constructively discharged him for that activity;
unlawfully enforced its facially-lawful dress code/apron policies against protected
concerted activity; and made a variety of Section 8(a)(1) threats to not engage in
protected concerted activity regarding racial harassment
e,
including that the Employer: disciplined/suspended the Charging Party for engaging
in protected concerted activity, and constructively discharged him for that activity;
unlawfully enforced its facially-lawful dress code/apron policies against protected
concerted activity; and made a variety of Section 8(a)(1) threats to not engage in
protected concerted activity regarding racial harassment. With regard to concert, the
Region concluded that the Charging Party’s conduct in continuing to wear the BLM
slogan on his work apron was intertwined with, and a “logical outgrowth” of, the
persistent and continuing concerted activity of the Charging Party and his coworkers
banding together to rid their workplace of racial harassment. After hearing back from
Advice on the scope of the notice-posting remedy, the Region resubmitted the case for
advice as to whether to include an alternative argument that the Charging Party’s
conduct in continuing to wear the BLM slogan was inherently concerted.

ACTION

We conclude that employee discussions in the workplace regarding racism should
be deemed inherently concerted because systemic racism, including an employer’s
racial discrimination, racial harassment, and/or tolerance of such discrimination or
harassment, necessarily implicates significant terms and condition of employment
and is of vital importance to employees. We further conclude that the Region should
urge the Board to expand the circumstances under which it applies the inherently
concerted doctrine beyond a conversation between two people to include the wearing
of a slogan or button.

As noted above, the Region concluded that the Charging Party’s conduct in
continuing to wear the BLM slogan on his work apron was intertwined with and a
“logical outgrowth” of the persistent and ongoing concerted activity of the Charging
Party and his coworkers banding together to rid their workplace of racial harassment
n between two people to include the wearing
of a slogan or button.

As noted above, the Region concluded that the Charging Party’s conduct in
continuing to wear the BLM slogan on his work apron was intertwined with and a
“logical outgrowth” of the persistent and ongoing concerted activity of the Charging
Party and his coworkers banding together to rid their workplace of racial harassment.
The Region should argue, alternatively, that the Charging Party’s individual wearing
of the BLM slogan on his work apron is concerted under the Board’s doctrine of
“inherently” concerted activity.

The inherently-concerted doctrine emerged in Trayco of South Carolina, Inc.,3
where the Board held that an employee’s discussions with her co-workers about
higher wages constituted concerted activity even though the discussions did not

3 297 NLRB 630 (1990), enforcement denied, 927 F.2d 597 (4th Cir. 1991).

Case 18-CA-273796

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contemplate group action. In reaching that decision, the Board observed that the
object of inducing group action need not be expressed but can instead be implied from
the subject matter of discussion. Because higher wages are a “frequent objective of
organizational activity,” the Board reasoned that the employee’s discussions about
that subject impliedly were concerted.4 The doctrine was enlarged in Aroostook
County Regional Ophthalmology Center,5 where the Board decided that discussions
about changes in work schedules were inherently concerted activity despite the
absence of any talk about the initiation of group action. Like wages, the Board
concluded that work schedules are a “vital term and condition of employment” that is
“likely to spawn collective action.”6 Lastly, in Hoodview Vending Co.,7 the Board
added the subject of “job security” to the list of vital terms and conditions of
employment that, when discussed between two or more employees, will be regarded
as inherently concerted activity
roup action. Like wages, the Board
concluded that work schedules are a “vital term and condition of employment” that is
“likely to spawn collective action.”6 Lastly, in Hoodview Vending Co.,7 the Board
added the subject of “job security” to the list of vital terms and conditions of
employment that, when discussed between two or more employees, will be regarded
as inherently concerted activity. Such discussions concern “the very existence of the
employment relationship and [will] quickly ripple through, and resonate with, the
work force.”8

The inclusion of racism among the subjects of workplace discussions deemed to be
inherently concerted activity is a logical and necessary extension of the inherently
concerted doctrine. As Advice has recognized previously, discussions concerning an
employer’s alleged discrimination raise the same considerations identified by the
Board with respect to discussion over other “vital” terms and conditions as a rationale
for finding them inherently concerted.9 The topics that have been deemed inherently
concerted to date all represent discrete terms and conditions of employment. Systemic
racism, including an employer’s racial bias or discrimination, by contrast, implicates
all terms and conditions of employment—including those the Board has already

4 Id. at 634; accord Automatic Screw Prods., 306 NLRB 1072, 1072 (1992), enforced
mem., 977 F.2d 582 (6th Cir. 1992).

5 317 NLRB 218 (1995), enforcement denied in part on other grounds, 81 F.3d 209
(D.C. Cir. 1996).

6 Id. at 220.

7 359 NLRB 355 (2014), vacated, 2014 WL 2929781 (Jun. 27, 2014), reconsidered &
affirmed, 362 NLRB 690 (2015).

8 Id. at 357.

9 See, e.g., SunBridge Healthcare LLC, d/b/a Milford Center, Case 01-CA-156820,
Advice Memorandum dated January 20, 2016, at 9-12 (arguing that workplace racial
discrimination is inherently concerted).
rounds, 81 F.3d 209
(D.C. Cir. 1996).

6 Id. at 220.

7 359 NLRB 355 (2014), vacated, 2014 WL 2929781 (Jun. 27, 2014), reconsidered &
affirmed, 362 NLRB 690 (2015).

8 Id. at 357.

9 See, e.g., SunBridge Healthcare LLC, d/b/a Milford Center, Case 01-CA-156820,
Advice Memorandum dated January 20, 2016, at 9-12 (arguing that workplace racial
discrimination is inherently concerted).

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identified as being inherently concerted, such as wages, work schedules, and job
security.

Indeed, the specter of workplace discrimination has been a matter of concern in
U.S labor law since the early days of the Act.10

The desire for fair and equitable conditions of employment on the part
of persons of any race, color or persuasion, and the removal of
discriminations against them by reason of their race or religious belief
is quite as important to those concerned as fairness and equity in
terms and conditions of employment can be to trade or craft unions or
any form of labor organization or association. Race discrimination by
an employer may reasonably be deemed more unfair and less excusable
than discrimination against workers on the ground of union
affiliation.11

Even after the passage of Title VII of the Civil Rights Act of 1964,12 the D.C. Circuit
recognized “an employer’s invidious discrimination on account of race or national
origin” as a significant threat to employees’ exercise of their Section 7 rights, noting
that “racial discrimination sets up an unjustified clash of interests between groups of
workers which tends to reduce the likelihood and the effectiveness of their working in
concert to achieve their legitimate goals under the Act.”13 Moreover, workplace

10 See, e.g., Vaca v. Sipes, 386 U.S. 171, 177 (1967) (tracing the union duty of fair
representation to judicial attempts to combat racial discrimination by unions certified
as exclusive bargaining representatives under the Railway Labor Act, citing Steele v
nd the effectiveness of their working in
concert to achieve their legitimate goals under the Act.”13 Moreover, workplace

10 See, e.g., Vaca v. Sipes, 386 U.S. 171, 177 (1967) (tracing the union duty of fair
representation to judicial attempts to combat racial discrimination by unions certified
as exclusive bargaining representatives under the Railway Labor Act, citing Steele v.
Louisville & N.R. Co, 323 U.S. 192 (1944), and Tunstall v. Bhd. of Locomotive
Firemen, 323 U.S. 210 (1944)). Cf. Sewell Mfg. Co., 138 NLRB 66, 72 (1962)
(overturning election because employer’s “propaganda directed to race . . . so inflamed
and tainted the atmosphere . . . that a reasoned basis for choosing or rejecting a
bargaining representative was an impossibility.”).

11 New Negro Alliance v. Sanitary Grocery Co., 303 U.S. 552, 561 (1938) (holding that
the picketing of a grocery store by black activists in protest of the store’s refusal to
hire black employees was a “labor dispute” under the Norris-LaGuardia Act and
therefore protected by Norris-LaGuardia’s anti-injunction protections).

12 42 U.S.C. § 2000e et seq. (1964).

13 United Packinghouse, Food & Allied Workers Int’l Union v. NLRB, 416 F.2d 1126,
1135 (D.C. Cir. 1969) (enforcing Board order directing employer to bargain over racial
discrimination and also holding on union’s petition for review that a policy or practice
ct and
therefore protected by Norris-LaGuardia’s anti-injunction protections).

12 42 U.S.C. § 2000e et seq. (1964).

13 United Packinghouse, Food & Allied Workers Int’l Union v. NLRB, 416 F.2d 1126,
1135 (D.C. Cir. 1969) (enforcing Board order directing employer to bargain over racial
discrimination and also holding on union’s petition for review that a policy or practice

Case 18-CA-273796

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discrimination is of significant importance to employees: “[i]t can hardly be argued,
given the history of race relations in this country, that alleviating racial
discrimination is not of interest to all employees in the workplace, irrespective of race
or ethnicity of the person….”14 And virtually every collective-bargaining agreement
contains an anti-discrimination provision, signifying the importance of this issue to
employees.

Similarly, an employer’s racial harassment, or tolerance of racial harassment,
has the potential to affect numerous terms and conditions of employment and is a
matter of great signifance to employees that is likely to spawn collective action.
Indeed, the facts of this case illustrate that concerns about such vital workplace
issues have the propensity to resonate with the workforce and lead to collective
action, as confirmed by the Charging Party’s and other employees’ concerted attempts
to get management to put an end to the ongoing racial harassment
matter of great signifance to employees that is likely to spawn collective action.
Indeed, the facts of this case illustrate that concerns about such vital workplace
issues have the propensity to resonate with the workforce and lead to collective
action, as confirmed by the Charging Party’s and other employees’ concerted attempts
to get management to put an end to the ongoing racial harassment.

Moreover, racial harassment in the workplace can be viewed, in essence, as an
issue of workplace health and safety.15 As Advice has previously found, discussions
concerning workplace health and safety are inherently concerted.16 Workplace health
and safety is undoubtedly one of the most vital terms and conditions of employment
from the perspective of employees, and such concerns often serve as a precursor to
organizing or other actions for mutual aid and protection.17 As the Board has

of discrimination against employees on the basis of race or national origin is a
violation of Section 8(a)(1)).

14 Dearborn Big Boy No. 3, Inc., 328 NLRB at 710, n.33. See also General Teamsters
Local Union No. 528, 237 NLRB 258, 261 (1978) (adopting an ALJ decision in which
the Judge commented that, “the right of employees to be free from racial
discrimination by an employer or union must be accorded the same primacy and
protection as the right to safe working conditions.”).

15 See generally Kathleen M. Pospenda, et al., Is Workplace Harassment Hazardous to
Your Health?, JOURNAL OF BUSINESS AND PSYCHOLOGY, Vol. 20 No. 1, 95-110 (2005)
(exposure to workplace harassment increases risk for illness, injury, or assault).

16 See North West Rural Electric Cooperative, Case 18-CA-150605, Advice
Memorandum dated September 21, 2015, at 9-12 (arguing that workplace safety and
health issues are inherently concerted); Renewal by Andersen LLC KC, Case 14-CA-
262563, Advice Memorandum dated Apr. 9, 2021, at 7-8 (same)
1, 95-110 (2005)
(exposure to workplace harassment increases risk for illness, injury, or assault).

16 See North West Rural Electric Cooperative, Case 18-CA-150605, Advice
Memorandum dated September 21, 2015, at 9-12 (arguing that workplace safety and
health issues are inherently concerted); Renewal by Andersen LLC KC, Case 14-CA-
262563, Advice Memorandum dated Apr. 9, 2021, at 7-8 (same).

17 E.g., Crossing Rehabilitation Services, 347 NLRB 228, 231 (2006) (employees
wanted union in order to negotiate over “concerns about safety at work, employment
benefits, and job security”); Snowshoe Co., 217 NLRB 1056, 1058 (1975) (employee

Case 18-CA-273796

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observed, “health and safety matters regarding unit employees’ workplaces are of
vital interest to employees,”18 and indeed, “[f]ew matters can be of greater legitimate
concern to individuals in the workplace . . . than exposure to conditions potentially
threatening their health, well-being, or their very lives.”19 Moreover, the resolution of
safety and health issues is a frequent objective of organizational activity likely to lead
to collective action for mutual aid or protection.20

Thus, we conclude that employee discussions in the workplace regarding racism
should be deemed inherently concerted.

We recognize that, even where topics are “inherently concerted,” the Board has
required that there be a conversation between employees about the relevant topic in
order to find concert.21 However, we conclude that the Board should expand the
circumstances under which it applies the inherently concerted doctrine beyond a
conversation between two people to include the wearing of a slogan or button in the
workplace. A button or slogan related to an inherently concerted topic and worn in the
workplace is effectively the start of a conversation among employees that is no
different from those already found to be inherently concerted in other contexts
under which it applies the inherently concerted doctrine beyond a
conversation between two people to include the wearing of a slogan or button in the
workplace. A button or slogan related to an inherently concerted topic and worn in the
workplace is effectively the start of a conversation among employees that is no
different from those already found to be inherently concerted in other contexts. Here,
the Charging Party’s wearing of the BLM slogan on his work apron could well have
led to more traditional discussions with coworkers regarding racism in the workplace

unionization efforts began for the purpose of “improving working conditions,
particularly safety measures, and wages”), enforced mem., 530 F.2d 969 (4th Cir.
1975).

18 Detroit Newspaper Agency, 317 NLRB 1071, 1071 (1995) (confirming relevancy of
union’s request for information addressing health and safety issues).

19 Minnesota Mining & Mfg. Co., 261 NLRB 27, 29 (1982) (finding that employer was
required to comply with union request for certain health and safety information),
enforced sub nom., Oil, Chemical & Atomic Workers Local Union No. 6-418 v. NLRB,
711 F.2d 248 (D.C. Cir. 1983).

20 E.g., Systems with Reliability, Inc., 322 NLRB 757, 757-60 (1996) (employees
discussed toxic effects of methyl ethyl ketone in their workplace before confronting
employer and threatening to contact OSHA); Detroit Newspaper Agency, 317 NLRB at
1071 (confirming relevancy of union’s request for audit report addressing health and
safety matters). See also In re AFL-CIO, 2020 WL 3125324 (D.C. Cir. 2020) (petition
seeking OSHA’s issuance of safety standard protecting against COVID-19 infections).

21 See Hoodview Vending, 359 NLRB at 358 n.16 (2012) (“Inherently concerted
activity involves a conversation between two or more individuals.”), incorporated by
reference in 362 NLRB No. 81, slip op. at 1.
ssing health and
safety matters). See also In re AFL-CIO, 2020 WL 3125324 (D.C. Cir. 2020) (petition
seeking OSHA’s issuance of safety standard protecting against COVID-19 infections).

21 See Hoodview Vending, 359 NLRB at 358 n.16 (2012) (“Inherently concerted
activity involves a conversation between two or more individuals.”), incorporated by
reference in 362 NLRB No. 81, slip op. at 1.

Case 18-CA-273796

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generally.22 Thus, like the preliminary discussions about vital terms in Hoodview
Vending, finding the wearing of the BLM slogan here to be inherently concerted
would prevent the Employer from rendering employees’ right to act in concert
meaningless by permitting the Employer to preemptively “shut down future
discussions and any other concerted actions that might follow.”23

Accordingly, absent settlement, the Region should argue, as an alternative to
traditional concert, that the Charging Party’s individual wearing of the BLM slogan
on his work apron was inherently concerted.

/s/

R.A.B.

ADV.18-CA-273796. Response.HomeDepot2

22 Although not necessary to a finding of inherent concert, we also note that, given the
particular context in which the Charging Party wore the BLM slogan, this action
could also have bolstered support for future action amongst the employees regarding
the alleged racially-motivated vandalism and/or encouraged others to come forward
with complaints about alleged harassment or the treatment of people of color in the
Employer’s workplace.

23 Id., slip op. at 4; see also Parexel Int’l, LLC, 356 NLRB No. 82, slip op. at 4.

(b) (6), (b) (7)(

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