Act recognizes undocumented laborers as employees. However, the supreme court case Hoffman Plastic Compounds, Inc. v. NLRB established that backpay could not be awarded to unlawfully fired undocumented employees due to the Immigration Reform and Control Act of 1986. In this court decision, it was also stated that the U.S. would support FLSA and MSPA, without regard to whether or not someone is documented. Undocumented workers also still have legal protection against discrimination based on national origin. The decision of the Hoffman supreme court case primarily has affected undocumented laborers by preventing them from getting backpay and/or reinstatement. While no undocumented individual is technically able to work in the United States legally, undocumented workers make up 5% of the workforce. In the U.S., people who were born outside of the country tend to work in riskier jobs and have a higher chance of encountering death on the job. The low wage sectors, which many undocumented people work in, have the highest rates of wage and hour violation. Estimates claim that 31% of undocumented people work in service jobs. Restaurant work in particular has a 12% rate of undocumented workers. Undocumented people can and have joined labor unions, and are even credited by a 2008 dissertation for "reinvigorating" the labor movement. Because the NLRA protects undocumented workers, it protects their right to organize. However the NLRA excludes workers that are agricultural, domestic, independent contractors, governmental, or related to their employers. The right to speak up against labor abuses was protected further by an immigration reform bill in 2013 with the POWER act, which intended to protect employees who spoke out against labor practices from facing detention or deportation. However, labor unions are not necessarily welcoming of immigrant workers. Within unions, there have been internal struggles, such as when Los Angeles immigrant janitors reorganized service workers. Being a part of the union does not necessarily address all the needs of immigrant workers, and thus winning power within the union is the first step for immigrant workers to address their needs. Immigrant workers often mobilize beyond unions, by campaigning in their communities on intersectional issues of immigration, discrimination, and police misconduct. Globalization In March 2004, the World Commission on the Social Dimension of Globalization issued a report called "A Fair Globalization: Creating Opportunities for All". The report acknowledges how potential globalization can affect labor rights. Reforming globalization will require cooperation not only within