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Eighth Circuit Vacates NLRB Order in Home Depot 'BLM' Apron Case

The panel vacated the NLRB order, leaving the question of NLRA protection for “BLM” insignia unresolved.

Overview

  • The court said the Board failed to properly apply the “special circumstances” test given local unrest, the store’s proximity to George Floyd’s death, and polarized views among employees and customers.
  • The case returns to the NLRB for a new balancing of Section 7 rights against documented business needs under the longstanding insignia framework.
  • Judges noted Home Depot enforced a neutral dress code that barred both “BLM” and pro-police messages and that managers suggested less political alternatives such as a DEI pin.
  • The decision vacates the Board’s reinstatement and back‑pay order from early 2024 that had reversed an administrative law judge and found the display protected concerted activity.
  • The ruling guides employers within the Eighth Circuit but does not set a nationwide rule, leaving continued uncertainty over workplace political and social messaging.