Central Hardware v. NLRB

In Central Hardware v. NLRB, 407 U.S. 539, 92 S.Ct. 2238, 33 L.Ed.2d 122 (1972), the Supreme Court distinguished Marsh v. Alabama, 326 U.S. 501, 66 S.Ct. 276, 90 L.Ed. 265 (1946), noting that Marsh involved a "company town" which the Court stated was "an economic anachronism rarely encountered today," 407 U.S. at 545, 92 S.Ct. at 2242. The Court declined to apply the rationale of Marsh to facilities such as parking lots and shopping centers, private property which to the extent it was open to the public, was open for limited designated purposes.