The right of workers in private employment to form unions and bargain collectively with their employers is guaranteed by the National Labor Relations Act (NLRA) and related federal laws. The NLRA is preemptive, meaning it supersedes state law in the areas it covers. For example, the Michigan Court of Appeals held that an employee covered by a collective bargaining agreement could not bring a breach of contract claim against his employer, because the claim was preempted by the NLRA (Flanagan v. Comau Pico, 733 N.W.2d 430 (Mich. Ct. App. 2007)). In areas not covered by the NLRA, such as the rights of public employees and the rights of private employees who are not engaged in interstate commerce, the states are free to make their own provisions. Additional information on Michigan law in areas not covered by the NLRA is available.