NYU Law professor Samuel Estreicher and Peter Rawlings, J.D., discuss the Second Circuit’s recent decision in Leslie v. Starbucks Corp., in which the court vacated a district court’s approval of broad subpoenas served by Starbucks on its employees in a proceeding for temporary injunctive relief under Section 10(j) of the National Labor Relations Act. Professor Estreicher and Mr. Rawlings argue that the Second Circuit’s emphasis on the need for discovery requests to be proportional to the limited inquiry in 10(j) proceedings, as well as its recognition of employees’ confidentiality interests in union organizing activities, may influence how courts evaluate such employer requests in future 10(j) litigation, particularly if the Supreme Court adopts a more stringent standard for granting 10(j) relief in the pending Starbucks v. McKinney case.