 For example, a number of employers have asserted that unions file frivolous lawsuits as part of such efforts, clogging the courts, taking the organizing process out of workers' hands and putting it into those of judges, and diverting resources from useful and efficient causes to "wasteful" legal causes.A second legal claim is that comprehensive campaigns are not protected activity under the NLRA.In 1958, the Supreme Court ruled in "NLRB v. Wooster Division of Borg-Warner Corp.," 356 U.S. 342, that unions are prohibited from striking over subjects of bargaining not encompassed by "wages, hours, and other terms or conditions of employment" (the phrase used in the NLRA).