A security guard company distributed an employee handbook containing work rules prohibiting employees from 1) complaining to clients, 2) solicitation and distribution of literature “at all times while on duty or in uniform,” and 3) fraternizing on or off duty with other employees. All three rules violate federal labor law which makes it an unfair labor practice for employers to interfere with, restrain, or coerce employees in exercise of their right to organize and enlist support, according to the Court. Guardsmark, LLC v. National Labor Relations Board