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LawMemo publishes Employment Law Memo.

NLRB Law Memo 06/30/2008
by Ross Runkel at LawMemo

NLRB Law Memo 06/30/2008
by
LawMemo - First in Employment Law.
Also by email.

NLRB - Staff summarized 1 decision.

RCC Fabricators, Inc. (4-CA-31757, 4-RC-20569, 20572; 352 NLRB No. 88) Southampton, NJ June 9, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35288.htm

The Board affirmed the administrative law judge's finding that foremen Ronald Earley and James Phillips were statutory supervisors based on the finding that they exercised independent judgment when assigning, and effectively recommending the assignment of, employees to departments and significant overall tasks.  In light of that finding, the Board did not pass on the judge's further finding that they possessed the power to discipline and effectively recommend discipline, and his alternative finding that foreman Phillips was the Respondent's agent.  In addition, the Board affirmed the judge's finding that Phillips unlawfully interrogated employees about a union meeting; however, it reversed the judge and dismissed the allegation that Phillips' questions about the union meeting created the impression of surveillance.  Finally, because of their supervisory status, the challenges to Earley's and Phillips' ballots were sustained.  Accordingly, the Board issued a certification of representative.

            The Respondent manufactures railroad equipment and structural steel components in a plant in Southampton, New Jersey.  At all times relevant to the proceedings, Carl Baer was the shop manager.  Under his supervision, James Phillips was foreman in charge of railroad construction operations, and Ronald Earley was foreman in charge of structural steel operations.  This consolidated C and R case involves a Nov. 21, 2002 election covering employees at the Respondent's Southampton facility.   The election resulted in 6 votes for and 5 against the Petitioner (Carpenters), with 5 challenged ballots.  In his initial decision, the judge found two Section 8(a)(1) violations involving interrogation and appearance of surveillance, and he dismissed allegations of threatened plant closure and discriminatory discharge.  The judge sustained the Respondent's challenge to the discharged employee's ballot, because of his discharge, and to the ballots of two laid-off employees, because they lacked a reasonable expectation of recall.  The Board, without ruling on these conclusions, remanded the case to the judge for further consideration in light of Oakwood Healthcare, Inc., 348 NLRB No 37 (2006), Croft Metals, Inc., 348 NLRB No. 38 (2006), and Golden Crest Healthcare Center, 348 NLRB No. 39 (2006).  The judge issued a supplemental decision on Jan. 30, 2007.

            The primary issue in this case was the supervisory status of foremen Phillips and Earley.  Both foremen attended weekly production meetings, and they met daily with shop manager Baer to discuss production goals and assignments.  The Board found sufficient evidence that the foremen exercised independent judgment in assigning and effectively recommending assignments in their respective production areas.

            On October 10, 2002, the day after employees met with union representatives at a local pizza parlor, foreman Phillips individually questioned two employees about the meeting, who attended, and what was said.  The Board found that Phillips' conduct constituted unlawful interrogation, but it did not create the impression of surveillance.

(Chairman Schaumber and Member Liebman participated.)

            Charges filed by Metropolitan Regional Council of Carpenters, Eastern Pennsylvania, State of Delaware, and Eastern Shore of Maryland; complaint alleged violations of Section 8(a)(1) and (3).  Hearing at Philadelphia, April 8 and 10, and May 15, 2003.  Adm. Law Judge Paul Buxbaum issued his decision Oct. 23, 2003, and his supplemental decision Jan. 30, 2007.



LawMemo publishes Employment Law Memo.

NLRB Law Memo 06/18/2008
by Ross Runkel at LawMemo

NLRB Law Memo 06/18/2008
by
LawMemo - First in Employment Law.
Also by email.

NLRB - Staff summarized 1 decision.

Tecumseh Packaging Solutions, Inc. (7-CA-49861; 352 NLRB No. 87) Tecumseh, MI June 2, 2008. 
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35287.htm

The Board reversed the administrative law judge's conclusion that the Respondent did not violate Section 8(a)(1) of the Act by maintaining a work rule that prohibited loitering on company property after working hours.  Citing Lutheran Heritage Village-Livonia, 343 NLRB 646 (2004), the Board found that employees could reasonably interpret the work rule as prohibiting Section 7 activity and, accordingly, the rule was overly broad, in violation of Section 8(a)(1).  The Board acknowledged that employers may have legitimate reasons for promulgating anti-loitering and similar work rules, and noted that its decision does not foreclose employers from adopting work rules that are narrowly tailored to address such legitimate concerns.

            (Chairman Schaumber and Member Liebman participated.)

Charge filed by Steelworkers; complaint alleged violation of Section 8(a)(1) and (5).  Hearing at Detroit on March 28, 2007.  Adm. Law Judge Karl H. Buschmann issued his decision July 16, 2007.



LawMemo publishes Employment Law Memo.

NLRB Law Memo 06/11/2008
by Ross Runkel at LawMemo

NLRB Law Memo 06/11/2008
by
LawMemo - First in Employment Law.
Also by email.

NLRB - Staff summarized 14 decisions.

Air Climate Systems, Inc. and All Climate Systems, Inc. (30-CA-17695; 352 NLRB No. 75) Janesville, WI May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35275.htm

The Board, granting the General Counsel's motion for default judgment, found that the Respondents (Air Climate Systems, Inc. and All Climate Systems, Inc.) were alter egos and a single employer and that the Respondents violated Section 8(a)(5) and (1) of the Act by withdrawing recognition from the Union, by failing to apply two collective-bargaining agreements, and by failing to provide information requested by the Union.  The Respondents filed the answer 1 day late and offered no explanation for the late filing.  The Board issued an order inviting the Respondents to file a response explaining the late filing of the answer.  The Respondents filed the response late and offered no explanation for the late filing of the response.  The response explained the late filing of the answer by stating that, on the day the answer was due, Respondents' counsel was delayed in returning to his office from a hearing.  The Board, applying Section 102.111(c) of the Board's Rules whereby a document may be filed late "only upon good cause shown based on excusable neglect," rejected the response as untimely filed.  The Board further found that the Respondents' explanation for the late filing of the answer set forth in the response showed only counsel inattention and noted that the Board has consistently rejected counsel inattention as an excuse for the late filing of an answer.

Chairman Schaumber noted that, as explained in his dissent in Patrician Assisted Living Facility, 339 NLRB 1153, 1156-1161 (2003), he would give weight to additional factors in deciding whether to grant a default judgment motion based on a late-filed answer.  However, he also noted that his view is not current Board law and that the additional factors were outweighed here by the weakness of the excuse for the late filing of the answer and by the late filing of the response.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

Allied Mechanical Services, Inc. (7-CA-40907, 41390; 352 NLRB No. 83) Kalamazoo, MI May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35283.htm

The Board denied the Respondent's motion for reconsideration of the Board's Sept. 28, 2007 supplemental decision and order (351 NLRB No. 5).  In that decision, the Board granted the General Counsel's and Union's motions for reconsideration and found that the Respondent violated Section 8(a)(5) and (1) of the Act by withdrawing recognition from Plumbers Local 357, revising its job application procedure without notice to Local 357, and failing to provide a response to Local 357's information request.

In its motion for reconsideration, the Respondent contended that the Board erred in retroactively applying its decision in Raymond F. Kravis Center for the Performing Arts, 351 NLRB No. 19 (2007).  In Kravis, the Board overruled the "due process" standard for union mergers and held that, following a union merger or affiliation, an employer's obligation to recognize and bargain with the union continues regardless of whether the union members were provided an opportunity to vote on the merger or affiliation.  The Respondent also contended that the Board erred in finding that the parties had a Section 9(a) relationship and in ordering the Respondent to recognize and bargain with the Union.  Additionally, the Respondent argued that the Board should remand the case to the judge to apply the Board's decision in Toering Electric Co., 351 NLRB No. 18 (2007).

            The Board found that the Respondent's motion failed to present extraordinary circumstances warranting reconsideration.  In finding its application of Kravis proper, the Board found that the Respondent could not have relied on the due process standard overruled by Kravis as well settled when it withdrew recognition of the union, because the Supreme Court's earlier decision in NLRB v. Financial Institution Employees (Seattle-First National Bank), 475 U.S. 192 (1986), cast grave uncertainty on that standard.  The Board also found that retroactive application of Kravis would further the purposes of the Act and that no particular injustice would arise from its retroactive application.

            Regarding the parties' bargaining relationship, the Board found no basis to reconsider its finding that the parties' 1991 settlement agreement demonstrated that the parties had established a 9(a) relationship.  That settlement agreement resolved a complaint that sought a Gissel bargaining order and alleged that the Respondent had committed numerous violations of Section 8(a)(1) and (3).  The Board noted that the settlement agreement's language, which required the Respondent to recognize and, upon request, bargain with the Union and embody in a signed collective-bargaining agreement any understanding reached, replicated the language of the complaint, which clearly contemplated a 9(a) relationship.

            The Board also found no basis to reconsider its separate finding that the Board's prior decision in Allied Mechanical Services, 332 NLRB 1600 (2001), was necessarily premised on the existence of a 9(a) relationship and barred the Respondent, under the principles of collateral estoppel, from relitigating whether the parties had a 9(a) bargaining relationship.  The Board rejected the Respondent's contention that the question of whether the parties' relationship was governed by 8(f) or 9(a) was not actually litigated in that case.

            Finally, the Board denied the Respondent's motion to remand the case to the judge to apply Toering Electric.  The Board found that the motion in this regard was untimely, because it concerned a portion of the case that the Board had decided in 2004.  Additionally, the Board found the motion without merit, because the Board's supplemental decision and order in this case issued before Toering was decided and, thus, did not fall within the ambit of the cases to which Toering applied.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

American Standard (8-CA-33352, et al.; 352 NLRB No. 80) Tiffin, OH May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35280.htm

The Board adopted the administrative law judge's findings that the Respondent committed numerous unfair labor practices during and after the parties' bargaining for a successor collective-bargaining agreement in April 2002.  The major issue was whether the parties reached a successor agreement in the late hours of April 30 and the early morning hours of May 1.  The Board adopted the judge's finding that the parties had not reached agreement or impasse, and that consequently the Respondent violated Section 8(a)(5) by abandoning negotiations. The Board concluded that the parties had agreed to continue negotiating over outstanding noneconomic issues and in fact did so in the early morning of May 1 after the private mediator employed by the parties had gone to bed.  Thus, the Board found it unnecessary to reach the issue of whether the judge erred in excluding the parties from introducing evidence involving the private mediator that the Respondent contended would establish that the parties reached agreement because the parties' subsequent conduct during the early hours of May 1-when the mediator was not present-established that there was no "meeting of the minds" on a successor agreement.

The Board rejected the General Counsel's request for extraordinary remedies, agreeing with the judge that its traditional remedies were sufficient to address the unfair labor practices found.  The Board also rejected the Respondent's argument that it had already remedied several violations as part of a set-aside settlement agreement.  The Board concluded that because the settlement had subsequently been set aside, the notices posted pursuant thereto had no effect and a new posting was appropriate.

(Chairman Schaumber and Member Liebman participated.)

            Charges filed by Glass, Molders, Pottery and Plastics Workers Local 7A; complaint alleged violation of Section 8(a)(1), (3), and (5).  Hearing at Tiffin on 22 days between July 23, 2003 and Sept. 29, 2005.  Adm. Law Judge Jane Vandeventer issued her decision Sept. 18, 2006.

                                                                        ***

Baptista's Bakery, Inc. (30-CA-17104, 17268, 30-RC-6604; 352 NLRB No. 72) Franklin, WI May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35272.htm

The Board reversed the administrative law judge's finding that the Respondent violated Section 8(a)(3) and (1) of the Act under a "mass layoff" theory by laying off five employees in order to discourage union activity.  Applying Wright Line, 251 NLRB 1083 (1980), enfd. 662 F.2d 899 (1st Cir. 1981), cert. denied 455 U.S. 989 (1982), the Board found that even assuming the General Counsel proved that antiunion animus was a motivating factor in the layoffs, the Respondent proved that it would have implemented the layoffs for economic reasons even in the absence of union activity.  The Board observed that at the time of the layoffs, the Respondent was entering its seasonal slow period with an increased workforce due to a prior expansion, that the expansion had been undertaken largely to accommodate anticipated business from two major customers, and that sales of those customers' products were not meeting expectations.  Having found that the layoffs were not unlawful, the Board sustained the Respondent's challenges to ballots cast by three of the alleged discriminatees.

The Board adopted the judge's finding that the Respondent did not violate Section 8(a)(3) and (1) by laying off employee Kathi Szuszka.  The Board agreed with the judge that Szuszka was not laid off.

The Board found it unnecessary to pass on whether the Respondent violated Section 8(a)(1) by giving employees free jackets in order to discourage support for the Union.  The Board found that the additional violation would be cumulative, because the judge had found that the Respondent violated Section 8(a)(1) by providing other benefits to employees, and the Respondent did not except to those findings.

In the absence of exceptions, the Board affirmed the judge's findings that the Respondent committed various violations of Section 8(a)(1) and affirmed the judge's dismissal of certain other Section 8(a)(1) allegations.  The Board also adopted the judge's recommendation for a second election based on objectionable conduct by the Respondent.

(Chairman Schaumber and Member Liebman participated.)

Charges filed by Teamsters Local 344; complaint alleged violations of Section 8(a)(1) and (3).  Hearing at Milwaukee, Feb. 21-24, April 3-7, and May 23-25, 2006.  Adm. Law Judge Mark D. Rubin issued his decision Dec. 22, 2006.

                                                                        ***

Bashas', Inc. (28-CA-21435, et al.; 352 NLRB No. 82) Phoenix, AZ May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35282.htm

The Board granted the General Counsel's request for special permission to appeal from the administrative law judge's ruling that the General Counsel must furnish the Respondent's counsel with the names of witnesses whom the General Counsel intends to call at the hearing, and reversed the judge's ruling.   The Board reasoned that by ordering the General Counsel to provide a list of witnesses in advance of their testimony, the judge effectively established a procedure for discovery, and that no provision of the Act or the Board's Rules and Regulations authorizes an administrative law judge to authorize discovery.  The Board noted that the General Counsel voluntarily agreed to provide advance notice of the dates on which current employees or managers of the Respondent, who are under subpoena, will be called, found that such voluntary agreements can aid in the efficient administration of the Act.  The Board further noted that there was no indication that the Respondent demonstrated a need for an advance witness list that could not have been  met by alternative measures, e.g., granting a continuance after the General Counsel's witnesses have testified.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

MJ Mueller, LLC d/b/a Benjamin Franklin Plumbing (18-CA-18216, et al.; 352 NLRB No. 71) North Branch, MN May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35271.htm

The Board adopted the administrative law judge's findings that the Respondent violated Section 8(a)(1) of the Act by discharging employees Donald Doty and Steven LaMont in retaliation for their protected activity in furtherance of a pay dispute with the Respondent.  In the absence of exceptions, the Board further adopted the judge's other findings that the Respondent violated Section 8(a)(1) and (5).

            Charges filed by Plumbers Local 34; complaint alleged violations of Section 8(a)(1), (3), and (5).  Hearing at Minneapolis on Oct. 16, 2007.  Adm. Law Judge David I. Goldman issued his decision Dec. 28, 2007.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

CNN America, Inc. and Team Video Services, LLC, Joint Employees (5-CA-31828, 33125 (formerly 2-CA-36129); 352 NLRB No. 85) Washington, DC May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35285.htm

The administrative law judge ruled, during the hearing, that (1) the Respondent must produce documents subpoenaed by the General Counsel and the Charging Party except to the extent that he specifically rules otherwise or defers making a decision on particular issues; and (2) the Respondent is not required to disclose confidential sources but must otherwise produce requested documents that the Respondent argues are subject to a reporter's privilege against disclosure.

            The Board granted the Respondent special permission to appeal the judge's denial of its petition to revoke the subpoenas.  The Board found, without reaching the merits of the Respondent's arguments that the subpoena requests are unduly burdensome, that the costs and burden of producing the vast number of documents requested in electronic format should be balanced against the relevance of and need for the documents.  The Board directed the chief administrative law judge to assign a separate administrative law judge to act as a special master and analyze these issues using the framework provided in a document called The Sedona Principles:  Best Practices, Recommendations & Principles for Addressing Electronic Document Production, Second Edition (The Sedona Conference Working Group Series, 2007).

Regarding the Respondent's claim of a reporter's privilege, the Board denied the Respondent's special appeal on the merits, finding that even assuming, without deciding, that the privilege applies, the General Counsel can overcome the privilege under the balancing test urged by the Respondent (whether the information sought can be obtained from alternative sources, whether the information is crucial to establishing the claim, and whether the need for the information outweighs the interest in protecting the substance of the reporter's newsgathering).  Accordingly, the Board remanded the proceeding to the chief administrative law judge for assignment of an administrative law judge to act as a special master to resolve the issues described above concerning the subpoenas.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

Dickens, Inc. (29-CA-28229; 352 NLRB No. 84) Commack, NY May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35284.htm

The Board adopted the administrative law judge's findings that the Respondent violated Section 8(a)(1) of the Act by ordering, instructing and requesting its employees to refrain from discussing bonuses with other employees, and by terminating Wenqing Lin for engaging in the protected concerted activity of requesting an increase in bonus rates.  Although the judge's finding that Respondent violated Section 8(a)(1) by instructing its employees not to discuss their bonuses with other employees was based on an unalleged violation, the Board found that the violation was related to the complaint.

            Chairman Schaumber recognized that the finding of a violation was consistent with extant Board law, which he applied for institutional reasons for the purpose of deciding this case.  Member Liebman found that the unalleged violation was closely connected to the subject matter of the complaint and was fully litigated.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by an individual; complaint alleged violations of Section 8(a)(1).  Hearing at Brooklyn, Aug. 20-21, 2007.  Adm. Law Judge Steven Fish issued his decision Dec. 4, 2007.

                                                                        ***

Engineered Steel Concepts, Inc. and ESC Group Limited, Alter Egos (13-CA-43235; 352 NLRB No. 73) East Chicago, IN May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35273.htm

The Board adopted the administrative law judge's findings that Respondent ESC Group Limited was the alter ego of Respondent Engineered Steel Concepts, Inc., that the Respondents and the Union had a Section 9(a) bargaining relationship, and that the Respondents violated Section 8(a)(1) of the Act by conditioning job offers to employees upon their working for a nonunion company without union wages and benefits; violated Section 8(a)(3) and (5) by laying off and subsequently terminating employees Wagner, Roop, and Miletich; and violated Section 8(a)(5) by failing and refusing to recognize and bargain collectively with the Union by refusing to apply the terms and conditions of their collective-bargaining agreement, including wage rates, fringe benefit fund contributions, and hiring hall provisions and by abrogating the agreement including the subcontracting of bargaining unit work.

            In adopting the judge's finding that the parties' relationship was governed by Section 9(a) rather than Section 8(f), the Board noted that the threshold question in determining the applicability of Section 8(f) is whether the employer is engaged primarily in the building and construction industry and that the burden of establishing that status lies with the party seeking to avail itself of the Section 8(f) statutory exception. The Board found that the Respondents, which were engaged principally in hauling steel byproduct between steel mills did not meet that burden because they failed to show that they were engaged primarily in the building and construction industry.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by Teamsters Local 142; complaint alleged violations of Section 8(a)(1), (3), and (5).  Hearing at Chicago, Feb. 12-13, 2007.  Adm. Law Judge Eric M. Fine issued his decision July 3, 2007.

                                                                        ***

Fresenius USA Mfg., Inc. (2-RC-23145; 352 NLRB No. 86) Chester, NY May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35286.htm

The Board, reversing the administrative law judge, set aside the election of Nov. 3, 2006, and directed that a new election be held.  The tally of ballots showed 9 votes for and 7 against the Petitioner, Teamsters Local 445.

            Two units of employees voted in this election (units A and B).  Unit A voted with green ballots and unit B with yellow ballots.  The Board agent, who was colorblind, incorrectly identified a ballot during the preelection conference.  During the election, although the party observers identified the color ballot voters should receive, the Board agent also incorrectly identified a ballot.  During the ballot count, the Board agent required that the Employer stand 6 to 8 feet away from the counting table, failed to display ballot markings, and refused the Employer's request to examine ballots.  These actions prevented the Employer from seeing any ballot markings.  Additionally, the Board agent took counted ballots home without securing them against any tampering, mishandling, or damage.

            Applying the standard set forth in Polymers, Inc., 174 NLRB 282 (1969), enfd. 414 F.2d 999 (2d Cir. 1969), cert. denied 396 U.S. 1010 (1970), the Board found that the cumulative effect of these irregularities raised a reasonable doubt as to the fairness and validity of the election.  The Board noted that "election procedures are designed to ensure both parties an opportunity to monitor the conduct of the election, ballot count, and determinative challenge procedure."  Paprikas Fono, 273 NLRB 1326, 1328 (1984).  The Board found that the Board agent prevented the Employer from verifying the accuracy of his count and interpretation of voter intent.  Additionally, the Board found that the agent's conduct after the count prevented the Board from saying with confidence that ballots remained in the identical condition as during the count.  Finally, the Board found that the agent's two mistakes in ballot identification cast further doubt on the fairness and validity of the election.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

Medco Health Solutions of Spokane, Inc. (19-CA-30143; 352 NLRB No. 78) Liberty Lake, WA May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35278.htm

The Board found that Section 8(a)(1) of the Act - refusal to furnish information and 8(a)(5) refusal to bargain allegations were not deferrable to arbitration and remanded the case to the administrative law judge for a full hearing on the merits.

            The case arose when the Respondent announced and implemented new performance standards and discipline structures for employees in its pharmacist and pharmacy units, but allegedly failed and refused to furnish information about the standards and structures when requested by the Union.  The information was relevant to the Union's requests for bargaining and its determination whether to grieve the performance standards and discipline structures.  The judge found that the 8(a)(5) allegation was arbitrable because the management rights provisions of the applicable collective-bargaining agreements addressed performance standards.  He found that the 8(a)(1) allegation also was arbitrable based loosely on the language of the agreements' recognition clauses and because the Respondent agreed not to challenge timeliness in an arbitration proceeding.

            Citing Team Clean, Inc., 348 NLRB No. 86 (2006), in which the Board reaffirmed its commitment to a policy against deferring information allegations, the Board found that the 8(a)(1) allegations should not have been deferred.  (Chairman Schaumber dissented in Team Clean, but concurred in applying it here for institutional reasons.)  Further, because the 8(a)(5) refusal to bargain allegations are inextricably related to the nondeferrable 8(a)(1) allegations, the Board found that they were not deferrable.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by Steelworkers Local 12-369; complaint alleged violation of

Section 8(a)(1) and (5).  Hearing at Spokane on Aug. 22, 2006.  Adm. Law Judge William G. Kocol issued his decision Sept. 12, 2006.

                                                                        ***

Operating Engineers Local 825 (22-CD-765; 352 NLRB No. 77) Newark, NJ May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35277.htm

The Board, in this jurisdictional dispute, concluded that Market Halsey employees are entitled to continue performing the work in dispute.  The work constituted "the operation of freight elevators at the Morgan Stanley construction project located at 165 Halsey Street, Newark, New Jersey."  The employer is Structure Tone, Inc.  Market Halsey is a party in interest.

            In finding that the dispute was properly before the Board pursuant to Section 10(k), the Board found that there were competing claims to the disputed work and the parties did not have an agreed-upon method for voluntary adjustment of the dispute.  In finding that Local 825 engaged in proscribed activity, the Board noted that this case was atypical because Local 825 directed its picketing at Structure Tone rather than Market Halsey, the party that employed the employee who performed the work in dispute.  The Board nevertheless found Section 8(b)(4)(D) applicable because it is intended to "protect not only employers whose work is in dispute from such [proscribed] activity, but any employer against whom a union acts with such a purpose."  Plumbers Local 195 (Gulf Oil), 275 NLRB 484, 485 (1985).

            Having found that the dispute was properly before the Board for determination, the Board considered all the relevant factors and awarded the work to Market Halsey employees.  Although the factor of collective-bargaining agreements favored awarding the work to employees represented by Local 825, the Board found that this factor was outweighed by the factors of employer preference and economy and efficiency of operations.  In doing so, the Board found that the factors of certifications, employer past practice, area practice, relative skills and training, and Joint Board determinations did not favor awarding the work to either group of employees.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***

Napa Ambulance Service, Inc., d/b/a Piner's Napa Ambulance Service (20-CA-32875;

352 NLRB No. 74) Napa, CA May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35274.htm

The Board adopted the administrative law judge's finding that the Respondent violated Section 8(a)(3) and (1) of the Act by issuing an employee a written warning because of her Union activities and because the Respondent equated union talk with activities prohibited by federal law.  In addition, the Board adopted the judge's findings that the Respondent did not violate Section 8(a)(3) and (1) by issuing an employee a warning for loud nonwork-related conversations and by terminating an employee for abandoning her shift and being dishonest.

            (Chairman Schaumber and Member Liebman participated.)

            Charge filed by an individual; complaint alleged violations of Section 8(a)(1) and (3).  Hearing at San Francisco, Aug. 14-18, 2006.  Adm. Law Judge James M. Kennedy issued his decision Dec. 20, 2006.

                                                                        ***

Trump Plaza Associates d/b/a Trump Plaza Hotel and Casino (4-RC-21263; 352 NLRB No. 76) Atlantic City, NJ May 30, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35276.htm

The Board affirmed the administrative law judge's overruling of the Employer's objections and adopted his recommendation for certification of the Union as the employees' representative. The Union won the election by a vote of 324 to 149, with 1 non-determinative challenged ballot. The Employer objected to the Union's use of letters and resolutions by elected officials as campaign propaganda and to elected officials' publicly conducting a mock card check and signing a "Certification of Majority Status" at a Union press conference and rally 6 days before the election.

            Regarding the elected officials' letters and resolutions (some of which neither expressly supported the Union nor related to the election at issue), the Board relied on Chipman Union, Inc., 316 NLRB 107 (1995), to find that the letters and resolutions would be recognized as the various elected officials' statements of opinion and would not confuse reasonable voters into believing that the Board favored the Union.

            Regarding the "Certification of Majority Status," the Board found that the record did not show that the Certification was disseminated among the voters.  Only 2 voters attended the press conference at which the Certification was signed, and no evidence was presented that any voters either saw a news report about the press conference or saw copies of the signed Certification document, which were available at the Union hall.  In view of the 175-vote margin favoring the Union, the Board found that such limited evidence of dissemination could not support an inference that the Certification could have influenced enough voters to affect the results of the election.

(Chairman Schaumber and Member Liebman participated.)

                                                                        ***



LawMemo publishes Employment Law Memo.

NLRB Law Memo 06/02/2008
by Ross Runkel at LawMemo

NLRB Law Memo 06/02/2008
by
LawMemo - First in Employment Law.

Also by email.

NLRB - Staff summarized 7 decisions.

Legal Services of Northern California (20-CA-32863; 352 NLRB No. 66) Sacramento, CA May 16, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35266.htm

The Board found that the Respondent violated Section 8(a)(5) of the Act by refusing to provide the Union with a requested copy of a separation agreement between the Respondent and employee Kimberly Dovey.

The administrative law judge rejected the Respondent's argument that the separation agreement was a confidential document on the grounds that the agreement's confidentiality provision was binding only on Dovey, and not the Respondent.  However, the judge concluded that the Respondent did not violate the Act by refusing to produce the separation agreement, finding that the separation agreement's sole purpose was to settle a potential tort claim between Dovey and the Respondent.

The Board agreed with the judge's rejection of the Respondent's confidentiality defense, but reversed the judge, finding instead that the Respondent violated the Act by refusing to provide the Union with a copy of the separation agreement.   The Board acknowledged that certain agreements between employees and employers are outside of the purview of a union's representational role, such as private tort settlements.  The Board found, however, that the separation agreement was not solely a private agreement between Dovey and the Respondent because it also served as a waiver of Dovey's rights under the collective-bargaining agreement. The Board concluded that the separation agreement was relevant to the Union's role of collective-bargaining representative and that the Respondent violated Section 8(a)(5) by refusing to provide it.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by Northern United Legal Assistance Workers, National Organization of Legal Services Workers, UAW Local 2320; complaint alleged violation of Section 8(a)(5) and (1).  Case submitted to the Division of Judges upon a joint motion of the parties seeking a decision based upon a hearing waiver and formal stipulation of facts signed on April 28, May 25 and 29, 2006.  Adm. Law Judge James M. Kennedy issued his decision Aug. 7, 2006.

***

Pennant Foods Co., a Wholly-Owned Subsidiary of CS Bakery Holdings, Inc., a Wholly-Owned Subsidiary of Chef Solutions Holdings, LLC (34-CA-11385, et al., and 34-RC-1925; 352 NLRB No. 62) North Haven, CT May 12, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35262.htm

The Board affirmed the administrative law judge's findings that the Respondent violated Section 8(a)(1) of the Act by: (1) interrogating employees; (2) threatening employees with loss of employment and closure of the facility if they selected the Union to represent them; and (3) threatening employees with loss of benefits if they selected the Union to represent them.  The Board additionally affirmed that the Respondent violated Section 8(a)(3) by: (1) devising and applying a light duty policy to deny a pro-union employee's reinstatement; (2) devising and applying a machine operator job description to deny a pro-union employee's reinstatement; and (3) denying employee Lee Mabry reinstatement following a workers' compensation leave of absence.  Further, the Board affirmed that the Union was precluded from seeking a Gissel bargaining order, and that several special remedies were warranted.  Finally, the Board denied the General Counsel's motion to strike Respondent's exceptions, but noted that it properly considered only arguments made in the Respondent's brief.

(Chairman Schaumber and Member Liebman participated.)

Charges filed by Auto Workers; complaint alleged violations of Section 8(a)(1) and (3).  Hearing at Hartford over 8 days between Oct. 25, 2006 and Jan. 10, 2007.  Adm. Law Judge Michael A. Marcionese issued his decision on Sept. 17, 2007.

***

Al & John Inc., d/b/a Glen Rock Ham and Noel Echavarria Gonzalez (22-CA-27477; 352 NLRB No. 69) Paterson, NJ May 22, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35269.htm

The Board adopted the administrative law judge's finding that the Respondent violated Section 8(a)(3) and (1) of the Act when it discharged employee Noel Echavarria Gonzalez.  In finding the violation, the Board did not rely on all of the factors cited by the judge.  First, the Board found that Echavarria Gonzalez engaged in union activity by circulating a union petition among other employees.  Second, the Board found that the Respondent had knowledge of that activity because Plant Manager Jon Udrija observed Echavarria Gonzalez circulating the petition.  Finally, the Board found that the Respondent's proffered reasons for the discharge were pretextual.  The Respondent had disciplined Echavarria Gonzalez for purported workplace misconduct on a day that the evidence of record reflects that he did not work.  The Respondent used the discipline as a factor supporting the discharge.  In finding evidence of pretext, the Board explicitly stated that it did not rely on the judge's findings as to whether the Respondent failed to act according to a disciplinary policy.

            The Board also denied the General Counsel's cross-exception seeking compound interest computed on a quarterly basis for any backpay awarded.  The Board was not prepared to deviate from its current practice of assessing simple interest.

            No party excepted to the judge's finding that the Respondent did not violate Section 8(a)(1) by engaging in unlawful surveillance of Echavarria Gonzalez.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by an Individual; complaint alleged violations of Section 8(a)(3) and (1).  Hearing at Newark on Oct. 23 and 30, 2007.  Adm. Law Judge Eleanor MacDonald issued her decision Feb. 13, 2008.

***

Hamilton Sundstrand (33-CA-15303; 352 NLRB No. 65) Rockford, IL May 19, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35265.htm

The Board adopted the finding of the administrative law judge that the Respondent violated Section 8(a)(5) and (1) of the Act by refusing to provide requested information to the Union.  The Board found that the information requested by the Union in Nov. 2006 concerning the Respondent's temporary ("yellow badge") employees was relevant to the Union's policing of the Respondent's contractual obligation to make an "earnest effort" to find "non-traditional work" for laid-off unit employees.  In finding that the Union demonstrated the relevance of the requested information, the Board rejected the Respondent's claim that the Union did not show that yellow badge work fits within the meaning of "non-traditional work" under Section 19.5C of the parties' collective-bargaining agreement.  The Board also found that the General Counsel showed that the relevance of the information should have been, and was, apparent to the Respondent under the circumstances.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by Auto Workers (UAW) Local 592; complaint alleged violations of Section 8(a)(1) and (5).  Hearing at Peoria on Nov. 13, 2007.  Adm. Law Judge George Carson II issued his decision Jan. 16, 2008.

***

Mega Force Productions Corp. (13-CA-44252; 352 NLRB No. 70) Chicago, IL May 23, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35270.htm

The Board issued a Decision and Order on Feb. 28, 2008, granting the General Counsel's motion for default judgment on the ground that the Respondent had failed to file an answer to the complaint or a response to the Notice to Show Cause.  352 NLRB No. 27 (2008).  The Board granted the Respondent's motion to vacate default judgment and for leave to file its appearance and answer to the complaint, and found that the documents in this case were inadvertently sent to an incorrect address.  Accordingly, the Board vacated its prior Decision and Order and remanded the proceeding to the Regional Director for further processing consistent with its Order.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by an Individual; complaint alleged violation of Section 8(a)(1).  The Board issued Decision and Order granting motion for default judgment on Feb. 28, 2008.

***

Wheeling Brake Block Mfg. Co. and Wheeling Brake Band & Friction Mfg. Co. (8-CA-34764, 35543; 352 NLRB No. 67) Bridgeport, OH May 23, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35267.htm

The Board adopted the findings of the administrative law judge that Respondent Wheeling Brake Block Mfg. Co. violated Section 8(a)(1) of the Act by telling employees that it was going to get rid of the Union and replace it with a union that it controlled, soliciting employees to assist in getting rid of the Union so that other employees would more readily accept the loss of the Union, implicitly or explicitly promising employees that by opposing the Union the employee would be recalled from layoff, and maintaining and enforcing an overly broad prohibition on union activity on its premises; Section 8(a)(3) and (1) by laying off and failing to recall employees for supporting the Union; and Section 8(a)(5) and (1) by repudiating the collective-bargaining agreement, including its seniority, pension contribution, and dues checkoff provisions, and refusing to recognize and bargain a successor collective-bargaining agreement with the Union.  In his supplemental decision, the judge found that Wheeling Brake Block Mfg. Co. was properly a respondent in this case, rejecting that entity's contention that it shut down or went out of business in 1999 and that Wheeling Brake Band & Friction Mfg. Co. was the sole surviving employing entity.  Wheeling Brake Block Mfg. Co. did not file exceptions to the judge's supplemental decision.

Because the General Counsel did not issue and serve an amended complaint on Wheeling Brake Band & Friction Mfg. Co., the Board, "out of an abundance of caution" did not "at this time" pass on whether Wheeling Brake Band & Friction Mfg. Co. is liable as a single employer with Wheeling Brake Block Mfg. Co. for the unfair labor practices found in this case.  The Board stated, however, that the General Counsel may plead and litigate the question of Wheeling Brake Band & Friction Mfg. Co.'s derivative liability during the compliance stage of this proceeding.

(Chairman Schaumber and Member Liebman participated.)

            Charges filed by Retail, Wholesale and Department Store Union, Local 379 and Food and Commercial Workers; complaint alleged violations of Section 8(a)(1), (3), and (5).  Hearing at St. Clairsville, Nov. 16, 2005; Supplemental Hearing at Steubenville, March 14, 2007.  Adm. Law Judge David I. Goldman issued his decision Dec. 9, 2005 and his Supplemental Decision May 31, 2007.

***

Windstream Corp. (6-CA-35483; 352 NLRB No. 68) Meadville, PA May 23, 2008.
http://www.nlrb.gov/shared_files/Board%20Decisions/352/v35268.htm

The Board affirmed the administrative law judge's findings, to which no party excepted, that the Respondent violated Section 8(a)(1) of the Act by promulgating and maintaining a policy prohibiting employees from discussing their compensation, benefits, and personnel records or information with others.  The Board granted the General Counsel and Charging Party's exceptions to the judge's failure to require the Respondent to post the Board's standard remedial notice, and the Board modified the Order accordingly.  The Board also ordered the Respondent to post the notice on its intranet and transmit it to employees via e-mail, consistent with the Board's adoption of the judge's finding in Windstream Corp., 352 NLRB No. 9 (2008), that the Respondent regularly communicates its employment policies to employees through e-mail.

            Chairman Schaumber agreed to the Order based on the particular circumstances of this case, noting the absence of exceptions to the judge's finding in the earlier Windstream case discussed above or to the judge's instruction in the instant case that the Respondent communicate its rule modification to employees electronically.

(Chairman Schaumber and Member Liebman participated.)

            Charge filed by Electrical Workers IBEW on behalf of its affiliated Locals 463, 1189, 1507, 1929, 2089, and 2374; complaint alleged violations of Section 8(a)(1).  Hearing at Pittsburgh, June 5, 2007.  Adm. Law Judge Wallace H. Nations issued his decision Aug. 9, 2007.

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