The case National Federation of Federal Employees, Local 1309 v. Department of the Interior et al., 1998 revolved around a dispute over collective bargaining agreements between federal employees and their employer. The National Federation of Federal Employees (NFFE) argued that the Department of Interior was required to negotiate over the conditions for drug testing in its workplace under section 7117(a)(1) of the Federal Service Labor-Management Relations Statute. However, this statute does not require negotiation on matters "specifically provided for by federal statute." The Supreme Court ruled in favor of the Department, stating that because Congress had already established guidelines for drug testing within civil service law, it fell into an exception category where no further negotiations were necessary. Therefore, NFFE's claim was dismissed as they could not force additional negotiations on issues already covered by existing laws.

In the dissenting opinion for National Federation of Federal Employees, Local 1309 v. Department of Interior et al., Justice Stephen Breyer argued that the majority's decision to uphold a ban on federal employees' use of government property for union activities was misguided. He contended that such restrictions were not necessary to maintain an efficient and effective government workforce, as claimed by the majority. Instead, he believed they could potentially undermine employee morale and productivity by limiting their ability to engage in collective bargaining activities during non-work hours or in non-work spaces within federal facilities. Furthermore, he disagreed with the majority's interpretation of relevant labor laws and regulations which led them to conclude that these prohibitions were legally justified. In his view, these legal sources did not clearly prohibit all uses of public resources for union purposes but rather left room for reasonable accommodations based on specific circumstances.