In Fleetwood Trailer, 389 U.S. 375, 88 S.Ct. 543, the Supreme Court was required to determine whether the employer violated the Act when it hired six new employees who had not previously worked for the company instead of six former strikers who had applied for reinstatement.
Holding that joint employer situation exists only when "two or more employers exert significant control over the same employees . . . [where] they share or co-determine those matters governing essential terms and conditions of employment"