In Hoffman Plastic Compounds, Inc. v. NLRB, 535 U.S. 137 (2002) the Supreme Court addressed the relationship between the Immigration Reform and Control Act (IRCA) and the National Labor Relations Act, two federal statutes. Specifically, the lower court had denied an employer's petition for review of an order from, the National Labor Relations Board in favor of an undocumented alien. Hoffman, 535 U.S. at 142. The employer had fired the employee when he began supporting unionization efforts. Id at 140. Finding this was an unlawful termination, the NLRB awarded backpay to the employee. On review, the Supreme Court vacated the NLRB's order. In doing so, it concluded that "awarding backpay to illegal aliens runs counter to policies underlying IRCA, policies the NLRB has no authority to enforce or administer." Id. at 149. The award therefore lay beyond the Board's remedial discretion. Id. In that case, the NLRB had fashioned a remedy of awarding back pay to an employee after his illegal firing. Discussing the history of NLRB remedies that were "generally broad," the Court noted that the NLRB's discretion was not unlimited. Id. at 142-43, Central to the Supreme Court's decision was the principle that the NLRB "had no authority to enforce or administer" policies underlying IRCA--a statute far removed from its expertise--and its award of back pay lay "beyond the bounds of the Board's remedial discretion." Id. at 149, The Court re-emphasized that "any 'perceived deficiencfy in the NLRA's existing remedial arsenal' must be 'addressed by congressional action,' not the courts." Id. at 152.