NEW YORK - The decision in Hoffman Plastic Compounds, Inc. v. NLRB (535 U.S. 137 $(2002$)) prohibits undocumented aliens from recovering back pay even when those employees did not violate the Immigration Reform and Control Act of 1986 (IRCA), the Second Circuit U.S. Court of Appeals ruled July 10 (Christian Palma, et al. v. National Labor Relations Board, No. 12-1199, 2nd Cir.; 2013 U.S. App. LEXIS 13911).