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Employees in health care facilities seeking to exercise their self-organizational rights have met strong opposition from employers who contend that the quality of patient care will be disrupted by union organization activity. Most hospitals have restricted or forbidden such union activity through a no solicitation-no distribution rule, forbidding employees from soliciting other employees for union membership and from distributing union literature, either within the hospital as a whole or in certain areas only. The validity of the no solicitation-no distribution rule in the hospital has been repeatedly challenged since the National Labor Relations Act (NLRA) was further amended in 1974 to include employees of nonprofit health care institutions. Prior to the 1974 amendments, private nonprofit hospitals had enjoyed an exemption from coverage under the NLRA.