Allentown Mack Sales & Service, Inc. v. NLRB, 522 U.S. 359, 29 (1998)

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Cite as: 522 U. S. 359 (1998)

Opinion of Rehnquist, C. J.

right to receive information, Kleindienst v. Mandel, 408 U. S. 753, 762-763 (1972), and to the right to solicit information or responses, Edenfield v. Fane, 507 U. S. 761, 765-766 (1993); Virginia Bd. of Pharmacy v. Virginia Citizens Consumer Council, Inc., 425 U. S. 748, 761 (1976). More specifically, we concluded in Thomas, supra, at 534, that union solicitation of employee views and support is protected First Amendment activity. In finding union solicitation protected, Thomas relied on Virginia Elec. & Power Co., supra, as establishing that employer's attempts to persuade employees were protected First Amendment activity. 323 U. S., at 536-537.

It is not, however, necessary to resolve whether the Board's standard violates the First Amendment in this case. It is sufficient that the Board's interpretation of § 8(a)(1) to limit sharply employer polling raises difficult constitutional issues about employers' First Amendment rights. We have held that when an interpretation raises such constitutional concerns, the Board's interpretation of the Act is not entitled to deference. Edward J. DeBartolo Corp. v. Florida Gulf Coast Building & Constr. Trades Council, 485 U. S. 568, 574-577 (1988); NLRB v. Catholic Bishop of Chicago, 440 U. S. 490, 506-507 (1979); see also Rust v. Sullivan, 500 U. S. 173, 190-191 (1991).

In DeBartolo, we held that the Board's interpretation of the Act to proscribe peaceful handbilling by a union was not permissible. The Court acknowledged the Board's special authority to construe the Act and the normal deference it is therefore accorded. The Court nevertheless concluded that the Board's interpretation was not entitled to deference because, "where an otherwise acceptable construction of a statute would raise serious constitutional problems, the Court will construe the statute to avoid such problems." 485 U. S., at 575. See also Bill Johnson's Restaurants, Inc. v. NLRB, 461 U. S. 731, 742-743 (1983) (the Board's interpretation of the Act is untenable in light of First Amendment concerns

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