evidence: Section 7 of the National Labor Relations Act (NLRA) states in part, "Employees shall have the right. . . to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection." Strikes are included among the concerted activities protected for employees by this section. The U.S. Supreme Court has upheld the right of employees to go on strike whether they have a union or not. Specifically, in 1962, the Supreme Court in NLRB v. Washington Aluminum upheld the NLRB’s decision that workers in a non-unionized workplace who walked out because it was too cold were protected under the NLRA and the employer could not fire them.