I don't know about the US but I remember a story where a garage got sued for copyright violation because its employees had the radio playing loudly (as expected in a noisy shop) and it could be heard outside, and therefore, it was considered a public performance. I think it was in France, or maybe Germany, where the right performance rights collecting society (SACEM for France, GEMA for Germany) is particularly aggressive.

It probably wouldn't have passed judgment, but it was enough to scare the shop into forbidding its employees to play music at work.