Centers While the Act requires an employer to permit distribution of literature by employees on non-working time in non-work areas, an employer may prohibit distribution at any time in work areas. See Stoddard-Quirk Mfg., 138 N.L.R.B. at 621. If special circumstances necessitate a more restrictive rule to maintain production and discipline, however, an employer may lawfully impose such a rule. Id. at 617 n.4, 620. When deciding whether an area is a work area as contemplated by Stoddard-Quirk, “the Board has looked at the quality and quantity of work, which occurs in the area at issue, and examines whether the work is more than de minimus [sic] and whether it involves production.” Brockton Hosp., 333 N.L.R.B. at 1375; see also Patio Foods v. NLRB, 415 F.2d 1001, 1003 (5th Cir. 1969) (<HOLDING>). More recently, the Board has deemed certain
holding that the defendants presence in a dark alleyway at six oclock in the morning behind a closed business in an exclusively commercial area supported the investigative stop and explaining that knowledge of recent burglaries in an area is a relevant circumstance to be considered in determining the reasonableness of an officers suspicion because knowledge of the character of the area is part of an officers expertise holding that a loading area was a work area notwithstanding the fact that employees used it for ingress and egress because the loading of trucks is no less a vital part of the production process because it is performed outside the plant building holding that the public use exception was not applicable because the injury to the tenants employee occurred in an area of the leased premises that was not open to the public but was used only by employees holding that it is not holding that because plaintiffs speech occurred in the reception area of the judge executives office it was only the nature of that limited area and not the general public nature of fiscal court budding within which the office was located that was determinative of the forum