After drafting an e-mail to his supervisor entitled "trouble brewing," and encouraging other employees to express to management their concerns about working conditions, Richard Luke was terminated by his employer for insubordination and disruptive behavior. Luke subsequently brought an action for wrongful termination in violation of public policy based on California Labor Code Section 232.5, which prohibits an employer from taking adverse action against an employee for disclosing information about the employer's working conditions. In Luke v. Collotype Labels USA, Inc., a California appellate court held that Luke's claim was preempted by the National Labor Relations Act ("NLRA") because the activities at issue were "concerted activities" arguably protected by the NLRA, and did not involve alleged violations of health and safety laws (which the court determined is the only wrongful termination in violation of public policy claim that is not subject to NLRA preemption).