Abstract
Part of an effective union‐free campaign is the ability to communicate with employees. While employers should always strive to act lawfully, innocent violations are usually remedied with assurances that similar conduct will not occur in the future. Injunctive relief has generally been uncommon and limited to egregious activities during an organizing campaign. However, as recently highlighted by a federal judge in Absolute Healthcare d/b/a Curaleaf Arizona (Curaleaf), Case No. 28‐CA‐267540, the line defining “egregious” may not be as distant as one might expect.
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