In Douglas Autotech Corporation, the National Labor Relations Board (NLRB) held that an employer lost its right under Section 8(d) of the National Labor Relations Act (NLRA) to terminate employees for striking illegally by imposing a lockout on them. By locking the workers out after the illegal strike ended, the employer effectively "re-employed" the workers, restoring their rights under the NLRA immunizing them from discipline for the illegal strike. Accordingly, the NLRB held that the employer unlawfully terminated the strikers.