increase the incentives that encourage illegal immigration. Withholding backpay would also frustrate collective bargaining rights of lawful U.S. workers under the NLRA, the court found: [T]he lack of a backpay remedy would make undocumented workers an easy target for employers resisting union organization, and, thus, frustrate the rights of lawful U.S. workers under the NLRA. An employer could intimidate United States citizens and other lawful residents by targeting undocumented workers for antiunion discharges. Or, alternatively, legal workers might be reluctant to organize in the first instance if the Board were unable to issue any remedy against illegal actions taken by employers against undocumented workers who support the union. Id. at 58. See also, e.g., Kolkka, 170 F.3d at 941 (<HOLDING>); Patel v. Quality Inn South, 846 F.2d 700, 704
holding union members state law claims for defamation against union preempted holding that a union agent did not engage in coercive conduct when he told employees that they should sign a petition stating they would vote for the union to  separate the men from the boys  holding that a union officials comments may be used to infer the object of union activity recognizing that union members interests are adequately represented by the union holding that irca does not limit the rights of undocumented workers to vote in union elections