Macy’s, Inc. (01-CA-123640; 365 NLRB No. 116) Saugus, MA, August 14, 2017
The Board (Chairman Miscimarra and Member McFerran; Member Pearce, dissenting) reversed the Administrative Law Judge’s conclusion that restrictions on the use of customer information from the Employer’s confidential records violate Section 8(a)(1). The majority found that, because the rules are limited to information contained in the confidential files of the Employer, they are lawful. Member Pearce would have adopted the judge’s conclusion that the restrictions are overly broad and violate Section 8(a)(1).
Charge filed by United Food and Commercial Workers Union, Local 1445. Administrative Law Judge Joel P. Biblowitz issued his decision on May 12, 2015. Chairman Miscimarra and Members Pearce and McFerran participated.
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Anheuser-Busch, LLC (03-CA-196263; 365 NLRB No. 123) Baldwinsville, NY, August 16, 2017.
The Board granted the General Counsel’s Motion for Summary Judgment in this test-of-certification case on the ground that the Respondent failed to raise any issues that were not, or could not have been, litigated in the underlying representation proceeding in which the Union was certified as the bargaining representative.
Charge filed by Teamsters Local 1149. Chairman Miscimarra and Members Pearce and McFerran participated.
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The Board granted the General Counsel’s Motion for Summary Judgment in this test-of-certification case on the ground that the Respondent failed to raise any issues that were not, or could not have been, litigated in the underlying representation proceeding in which the Union was certified as the bargaining representative. Chairman Miscimarra noted that he would have granted review in the underlying representation proceeding regarding the Acting Regional Director’s finding that the Respondent’s Licensed Vocational Nurses (LVNs) are not statutory supervisors, but he agreed that the Respondent had not raised any new matters that are properly litigable in this unfair labor practice proceeding.
Charge filed by Service Employees International Union, Local 2015. Chairman Miscimarra and Members Pearce and McFerran participated.
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The Board granted the General Counsel’s Motion for Default Judgment based on the Respondent’s failure to file an answer to the compliance specification. The Board ordered the Respondent to pay the make-whole medical expenses owed to discriminatees pursuant to the Board’s unpublished Decision and Order approving a Formal Settlement Stipulation entered into by the parties and enforced by a court of appeals. The Board declined the General Counsel’s request to order the Respondent to mail the Notice to its employees, noting that this remedy was not included in the Board’s original Order; because that Order has been enforced by a court, the Board no longer possess jurisdiction to modify it.
Charge filed by Teamsters Local Union No. 838, affiliated with International Brotherhood of Teamsters. Chairman Miscimarra and Members Pearce and McFerran participated.
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The Board adopted the Administrative Law Judge’s conclusions that the Respondent violated Section 8(a)(1) by unlawfully interrogating employees regarding Union support, unlawfully disciplining five employees and discharging two employees for their participation in a lawful strike, and unlawfully threatening employees with retaliation for participation in further protected activity. The Board reversed the judge’s findings of three other violations—unlawful interrogation, creating an impression of surveillance, and threatening employees with job loss—finding these allegations were time-barred under Section 10(b). The majority (Members Pearce and McFerran) also adopted the judge’s finding that a notice reading was appropriate in this case; Chairman Miscimarra did not find the violations sufficiently “widespread” to warrant this remedy. Chairman Miscimarra also maintained his opposition to remedies awarded pursuant to King Soopers, Inc., 364 NLRB No. 93 (2016).
Charges filed by 32BJ SEIU New England 615. Administrative Law Judge Kenneth W. Chu issued his decision on October 12, 2016. Chairman Miscimarra and Members Pearce and McFerran participated.
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The Board (Members Pearce and McFerran; Chairman Miscimarra, dissenting) denied the Employer’s Request for Review of the Acting Regional Director’s Decision on Objections and Certification of Representative as it raised no substantial issues warranting review. The majority concluded that the evidence produced by the Employer was insufficient to demonstrate that its care managers are statutory supervisors because they assign or responsibly direct other employees. Chairman Miscimarra would grant review and find that the Acting Regional Director’s findings of fact support the conclusion that the care managers are statutory supervisors because they have the authority to assign and responsibly direct other employees. Chairman Miscimarra would remand the case to the Acting Regional Director to decide whether the election must be set aside on the basis that the care managers were supervisors who engaged in objectionable prounion conduct.
In denying review, the same majority found that the Acting Regional Director did not abuse his discretion by refusing to enforce the Employer’s subpoena duces tecum upon one of its clinical directors, an admitted supervisor, to produce texts, emails, and other social media postings in her possession regarding the Petitioner’s campaign. Chairman Miscimarra would grant review on this issue as well, and on remand, would direct the Acting Regional Director to reopen the record, enforce the subpoena, and permit the Employer to introduce further evidence obtained through the subpoena regarding any prounion conduct engaged in by the clinical director.
Petitioner – District 1199C, National Union of Hospital and Health Care Employees, AFSCME, AFL-CIO. Chairman Miscimarra and Members Pearce and McFerran participated.
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The Board adopted the Administrative Law Judge’s conclusions that: (1) deferral to arbitration is inappropriate; (2) the Union’s information request was not pre-arbitral discovery; and (3) the Respondents violated Section 8(a)(5) by failing to provide information requested by the Union. The Board also denied the Respondents’ motion to reopen the record to introduce into evidence a Federal District Court’s order dismissing a lawsuit related to the arbitration in this case and remanding the dispute to the arbitrator without prejudice for a final decision on all issues. The Board took administrative notice of the court order and thus found it unnecessary to pass on the Respondents’ motion. The Board further observed that the order did not alter the Respondents’ obligation to furnish the information in issue.
Charges filed by 1199, SEIU United Healthcare Workers East. Administrative Law Judge John T. Giannopoulos issued his decision on September 14, 2016. Chairman Miscimarra and Members Pearce and McFerran participated.
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The Board adopted the Administrative Law Judge’s conclusions that the Respondent violated Section 8(a)(3) and (1) by: (1) ceasing to assign work to its drivers following their choice to unionize, and (2) conditioning the employees’ reinstatement on their rejection of the Union. The Board also adopted the judge’s conclusion that the Respondent violated Section 8(a)(5) and (1) by bypassing the Union and dealing directly with the bargaining unit employees regarding their terms and conditions of employment.
Charges filed by an individual. Administrative Law Judge Benjamin W. Green issued his decision on February 8, 2017. Chairman Miscimarra and Members Pearce and McFerran participated.
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In this Decision on Review, the Board (Members Pearce and McFerran; Chairman Miscimarra, dissenting) found that crewmembers who produce electronic content displayed on the “center-hung board” during professional basketball games are statutory employees covered by the Act, not—as the Regional Director had found—independent contractors. In so finding, the majority applied the approach set forth in FedEx Home Delivery, 361 NLRB No. 55 (2014). The majority found that the Employer had not established that the crewmembers were independent contractors as many of the relevant factors supported employee status, and the remainder were inconclusive. The majority stated that, even if the inconclusive factors were found to support independent contractor status, the Employer still had not carried its burden to establish that crewmembers are independent contractors. Chairman Miscimarra would have found that the Regional Director correctly concluded that the crewmembers are independent contractors. He also reiterated his disagreement with the FedEx standard.
Petitioner – International Alliance of Theatrical Stage Employees. Chairman Miscimarra and Members Pearce and McFerran participated.
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R Cases
Sysco Columbia, LLC (10-RC-195759) Columbia, SC, August 16, 2017. The Board denied the Employer’s Request for Review of the Regional Director’s determination to hold the representation petition in abeyance pending resolution of the outstanding unfair labor practice charges as it raised no substantial issues warranting review. Chairman Miscimarra stated that he favors a reconsideration of the Board’s blocking charge doctrine for the reasons expressed in his and former Member Johnson’s dissenting views to the Board’s Election Rule, 79 Fed. Reg. 74308 at 74430-74460 (Dec. 15, 2014), but he acknowledged that the Board has declined to materially change its blocking charge doctrine, which was the basis for the Regional Director’s determination to hold the petition in abeyance. He noted that, more generally, this case involves the application of the Board’s Election Rule, with which he continues to disagree for the reasons stated in the dissent regarding the Rule, supra. Petitioner – Teamsters Local Union 509. Chairman Miscimarra and Members Pearce and McFerran participated.
Sysco Columbia, LLC (10-RC-194843) Columbia, and various other locations in SC, and Augusta, GA, August 16, 2017. The Board denied the Employer’s Request for Review of the Regional Director’s determination to hold the representation petition in abeyance pending resolution of the outstanding unfair labor practice charges as it raised no substantial issues warranting review. Chairman Miscimarra stated that he favors a reconsideration of the Board’s blocking charge doctrine for the reasons expressed in his and former Member Johnson’s dissenting views to the Board’s Election Rule, 79 Fed. Reg. 74308 at 74430-74460 (Dec. 15, 2014), but he acknowledged that the Board has declined to materially change its blocking charge doctrine, which was the basis for the Regional Director’s determination to hold the petition in abeyance. He noted that, more generally, this case involves the application of the Board’s Election Rule, with which he continues to disagree for the reasons stated in the dissent regarding the Rule, supra. Petitioner – Teamsters Local Union 509. Chairman Miscimarra and Members Pearce and McFerran participated.
CTS Construction, Inc. (09-RD-187368) Cincinnati, OH, August 17, 2017. The Board denied the Employer’s and the Petitioner’s Motions for Reconsideration of the Board’s May 31, 2017 Order and its July 26, 2017 Erratum denying their Requests for Review of the Regional Director’s administrative dismissal of the decertification petition. The Board found that neither party had demonstrated extraordinary circumstances warranting reconsideration under Section 102.65(e)(1) of the Board’s Rules and Regulations. In agreeing that the Employer’s motion should be denied, Chairman Miscimarra adhered to the position expressed in his dissent that review should have been granted because substantial questions exist regarding whether the Employer and the Union had bargained for a reasonable period of time under the settlement agreement. Petitioner – an Individual. Union – Communications Workers of America, AFL-CIO, (CWA), Local 4322. Chairman Miscimarra and Members Pearce and McFerran participated.
C Cases
United States Postal Service (16-CA-151622, et al.) Dallas and Carrolton, TX, August 14, 2017. The Board approved a formal settlement stipulation between the Respondent, the Charging Party, and the General Counsel, and specified actions the Respondent must take to comply with the Act. Charges filed by National Association of Letter Carriers, Branch 132, affiliated with National Association of Letter Carriers, AFL-CIO; National Postal Mail Handlers Union, Local 311, affiliated with National Postal Mail Handlers Union, AFL-CIO; American Postal Workers Union, Dallas Area Local 732, affiliated with American Postal Workers Union, AFL-CIO. Chairman Miscimarra and Members Pearce and McFerran participated.
Speedway Redimix, Inc. and Speedway Construction Products Corp., as a Single Employer (25-CA-176012 and 25-CA-176052) Fort Wayne, IN, August 14, 2017. The Board denied the Charging Party’s Request for Special Permission to Appeal the Administrative Law Judge’s ruling denying it permission to present evidence in support of an additional remedy. The denial was without prejudice to the Charging Party’s right to renew its arguments before the Board on any exceptions that may be filed to the judge’s decision, if appropriate. Charges filed by Chauffeurs, Teamsters and Helpers Local Union No. 414 a/w The International Brotherhood of Teamsters. Chairman Miscimarra and Members Pearce and McFerran participated.
International Brotherhood of Teamsters, Local No. 251 (Rhode Island Hospital) (01-CB-172600) Providence, RI, August 14, 2017. No exceptions having been filed to the June 30, 2017 decision of Administrative Law Judge Paul Bogas’ finding that the Respondent had not engaged in certain unfair labor practices, the Board adopted the judge’s findings and conclusions, and dismissed the complaint. Charge filed by an individual.
Trey Harlin, P.C. (16-CA-171972) Fort Worth, TX, August 14, 2017. No exceptions having been filed to the June 30, 2017 decision of Administrative Law Judge Sharon Levinson Steckler’s finding that the Respondent had not engaged in certain unfair labor practices, the Board adopted the judge’s findings and conclusions, and dismissed the complaint. Charge filed by an individual.
McCarthy Law PLC (28-CA-175313 and 28-CA-181381) Scottsdale, AZ, August 14, 2017. No exceptions having been filed to the June 30, 2017 decision of Administrative Law Judge Mary Miller Cracraft’s finding that the Respondent had not engaged in certain unfair labor practices, the Board adopted the judge’s findings and conclusions, and dismissed the complaint. Charges filed by individuals.
Los Angeles LGBT Center (31-CA-192549) Los Angeles, CA, August 14, 2017. The Board denied the Employer’s Petition to Revoke an investigative subpoena duces tecum. The Board found that the subpoena sought information relevant to the matter under investigation and described with sufficient particularity the evidence sought, and that the Employer failed to establish any other legal basis for revoking the subpoena. Although Chairman Miscimarra would evaluate the subpoena without consideration of the Region’s post-petition modification of the time period, he joined his colleagues in denying the petition because he agreed that the time period in the subpoena’s original request was reasonable and relevant to matters under investigation. Charge filed by Service Employees International Union (SEIU), CTW-CLC, Local 721. Chairman Miscimarra and Members Pearce and McFerran participated.
Everport Terminal Services, Inc. (32-CA-172286 and 32-CB-172414) Oakland, CA, August 15, 2017. The Board granted the Unions’ request for Special Permission to Appeal the Administrative Law Judge’s rulings ordering an in camera review of disputed documents in their privilege logs and later ordering the production of certain documents to the General Counsel. The Board denied the appeal on the merits, finding that the Unions failed to establish that the judge abused her discretion. Charges filed by International Association of Machinists & Aerospace Workers, District Lodge 190, Local Lodge 1546, AFL-CIO, and International Association of Machinists and Aerospace Workers, District Lodge 190, Local Lodge 1414, AFL-CIO. Chairman Miscimarra and Members Pearce and McFerran participated.
Bob’s Tire Co., Inc., and B.J.’s Service Company, Inc. (a Joint Employer) (01-CA-169949, et al.) New Bedford, MA, August 15, 2017. The Board denied the Respondent’s Motion to Dismiss the Complaint, finding that the Respondent failed to establish that the complaint fails to state a claim and that it is entitled to judgment as a matter of law. The Board noted that the Respondent’s original request for a bill of particulars was not before the Board, as Deputy Chief Administrative Law Judge Arthur J. Amchan granted the request in part and ordered the General Counsel to clarify certain aspects of the complaint. Charges filed by United Food and Commercial Workers International Union, Local 328. Chairman Miscimarra and Members Pearce and McFerran participated.
United States Postal Service (28-CA-175106) Las Vegas, NV, August 18, 2017. The Board denied the Respondent’s Motion to Dismiss the complaint. The Board found that the Respondent failed to demonstrate that certain complaint allegations were barred by a settlement agreement in a prior case, determining that the settlement prevented the General Counsel from alleging that the maintenance of a rule was unlawful under the “reasonably construe” prong of Lutheran Heritage Village-Livonia, 343 NLRB 646 (2004), but did not preclude litigation over whether the rule had been unlawfully applied post-settlement to restrict employees’ exercise of their Section 7 rights. The Board also found that the Respondent failed to establish that the allegations exceeded the scope of the charge. In addition, the Board found that the Respondent’s contention that some complaint allegations were also the subject of an ongoing consolidated proceeding did not currently constitute grounds for dismissal of the allegations in this proceeding. Charge filed by an individual. Chairman Miscimarra and Members Pearce and McFerran participated.
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Brusco Tug & Barge, Inc., Board Case No. 19-CA-096559 (reported at 362 NLRB No. 115) (D.C. Cir. decided August 15, 2017)
In an unpublished judgment, the Court enforced the Board’s bargaining order issued against this tugboat operator. In doing so, the Court upheld the Board’s representation-case finding that the Employer did not carry its burden of proving that its mates are supervisors excluded from coverage under Section 2(11) of the Act.
The case has a lengthy procedural history that began in 1999 with an election petition filed by International Organization of Masters, Mates & Pilots, ILA, AFL-CIO, seeking to represent a unit of the Employer’s captains, mates, engineers, and deckhands on vessels operating out of its home port in Longview/Cathlamet, Washington. In the representation-case proceeding that was currently under review, the Regional Director, applying the standards of Oakwood Healthcare, Inc., 348 NLRB 686 (2006), found that the mates did not assign or responsibly direct deckhands using independent judgment, as the Employer had asserted. The Regional Director therefore certified the Union as the employees’ collective-bargaining representative on the tally of ballets of the election previously held in the petitioned-for unit. After granting the Employer’s Request for Review, the Board issued a decision affirming the Regional Director’s decision. Thereafter, the Employer refused to bargain to obtain court review of the certification.
The Court upheld the certification on the basis of substantial evidence and “the Board’s faithful application of the standards articulated in Oakwood.” The Court explained that the record demonstrated that the mates “make only obvious or self-evident work assignments that do not require independent judgment,” and that the Employer had “not identif[ied] any occasion in which a mate was disciplined or faced adverse consequences because of a deckhand’s poor performance.” Finally, the Court held that the Board did not abuse its discretion in denying the Employer’s motion to submit evidence of employee turnover, noting that it is well settled that post-election turnover is an insufficient ground to set aside an election.
The Court’s unpublished judgment may be found here.
Convergys Corporation, Board Case No. 14-CA-075249 (reported at 363 NLRB No. 51) (5th Cir. decided August 7, 2017), and Logisticare Solutions, Inc., Board Case No. 16-CA-134080 (reported at 363 NLRB No. 85) (5th Cir. decided August 9, 2017)
In a pair of published opinions, the Court granted the Employers’ petitions for review. In each case, the panel majority based its primary conclusion on a holding that it was bound by the contrary, in-circuit precedent of Murphy Oil USA, Inc. v. NLRB, 808 F.3d 1013 (5th Cir. 2015), petition for reh’g en banc denied (5th Cir. 2016), cert granted, 137 S. Ct. 809 (2017), and D.R. Horton v. NLRB, 737 F.3d 344 (5th Cir. 2013), petition for reh’g en banc denied (Apr. 16, 2014). Unlike those earlier cases, neither case involved an arbitration agreement.
In Convergys, the Board (then-Chairman Pearce and Member McFerran; then-Member Miscimarra, dissenting) found that the Employer violated Section 8(a)(1) by requiring prospective employees to sign job applications that included a provision waiving their Section 7 rights to bring or otherwise participate in a class, joint, or collective action, and by attempting to enforce the waiver in court. The panel majority also affirmed the Administrative Law Judge’s finding that the Employer violated Section 8(a)(1) by enforcing its mandatory waiver through its motion to strike the class and collective allegations in a wage-hour lawsuit filed by the Charging Party. In dissent, then-Member Miscimarra argued that the Board does not have authority to dictate the procedures for litigating claims that do not arise under the Act, and that the Act protects employees’ rights to bring claims individually. He also would have found that the Employer’s motion to strike was protected by the First Amendment’s Petition Clause.
On review in Convergys, the panel issued a fractured decision. Circuit Judge Elrod authored the panel majority opinion, which held that, under the Fifth Circuit’s Murphy Oil and D.R. Horton decisions, the Employer did not act unlawfully in requiring applicants to sign the waiver or by seeking to enforce the waiver. Dissenting, Circuit Judge Higginbotham explained that those Fifth Circuit cases were not controlling here, where there was no agreement to arbitrate. Concurring in the judgment, Circuit Judge Higginson was “persuaded by Judge Higginbotham’s thoughtful conclusion,” but agreed with Judge Elrod that “our rule of orderliness forecloses our ability to take that position in this case.” That said, Judge Higginson stated that, if writing on a “clean slate,” he “would urge this court [to] adopt Chief Judge Wood’s and Chief Judge Thomas’s reasoned understandings of Section 7’s scope” which held to the contrary, citing Lewis v. Epic System Corp., 823 F.3d 1147 (7th Cir. 2016), cert. granted, 137 S. Ct. 809 (2017); Morris v. Ernst & Young, LLP, 834 F.3d 975 (9th Cir. 2016), cert. granted, 137 S. Ct. 809 (2017).
In Logisticare, the same divided Board panel, citing its decision in Convergys, found that the Employer similarly violated Section 8(a)(1) by maintaining a rule that requires employees, as a condition of employment, to waive their rights to pursue class or collective action lawsuits. The panel majority also found that the Employer’s rule was independently unlawful because, given the agreement’s ambiguity about whether employees could file unfair-labor-practice charges with or on behalf of other employees, employees would reasonably read the rule as restricting their right to file charges with the Board. In dissent, then-Member Miscimarra disagreed with both findings.
On review in Logisticare, the same divided panel decided the case. Judge Elrod authored the panel majority opinion, citing Murphy Oil and D.R. Horton, to hold that the Employer did not act unlawfully in requiring applicants to sign the waiver, and also rejected the Board’s finding that the Employer’s rule was independently unlawful because employees would reasonably read the rule as restricting their right to file charges with the Board. Judge Higginbotham dissented in part on the basis of his dissenting opinion in Convergys, but concurred in the majority decision’s rejection of the independent violation. Judge Higginson dissented in part, stating that he would have upheld the independent violation, but otherwise concurred in the judgment, as explained in his concurring opinion in Convergys.
The Court’s opinion in Convergys is here (link is external). The Court’s opinion in Logisticare is here (link is external).
Midwest Division-MMC, LLC d/b/a Menorah Medical Center, Board No. 17-CA-088213 (reported at 362 NLRB No. 193) (D.C. Cir. decided August 18, 2017)
In a published opinion, the Court, in all respects but one, enforced the Board’s order issued against this acute-care hospital located in Overland Park, Kansas, which is party to a collective-bargaining agreement with the National Nurses Organizing Committee – Kansas/National Nurses United covering its registered nurses. The Court’s disagreement with the Board was on the application of NLRB v. J. Weingarten, Inc., 420 U.S. 251 (1975) (recognizing the right of an employee to refuse to submit, without union representation, to an interview which he reasonably fears may result in his discipline), to the circumstances of this case.
Pursuant to Kansas state law and regulations, the Employer developed an internal risk-management plan to monitor the standard of care provided to patients. The plan established a system of reporting, investigating, and evaluating incidents where there was a question whether the standard of care had been met. The plan included a nursing peer review committee that is required to report violations of a certain level to the Kansas State Board of Nursing. The plan also contained a confidentiality provision that prohibited employees, without authorization, from disclosing “information concerning reportable incidents,” to anyone except hospital officials, risk-management officials and committees, and state licensing agencies. In May 2012 and February 2013, two nurses, whose conduct was being investigated by the committee, requested union representation during the proceedings, which the Employer denied. After the first nurse was denied representation, the Union requested information on various aspects of the committee’s workings, as well as certain documents submitted by employees to the committee and the committee’s decisions on whether to report incidents to the state licensing board.
The Board (then-Chairman Pearce and Members Hirozawa and Johnson) found that the Employer violated Section 8(a)(1) by denying the nurses’ Weingarten requests for Union representation at the peer review committee proceedings. In doing so, the Board rejected the Employer’s claim that the committee was beyond the Board’s jurisdiction because it was a “political subdivision” under Section 2(2). The Board also found that the Employer’s confidentiality rule was unlawful under Section 8(a)(1) because it prohibited employees from discussing discipline and ongoing investigations with other employees and their Union representatives. Finally, the Board (Member Johnson, dissenting) found that the Employer violated Section 8(a)(5) and (1) by refusing to furnish the Union with the requested information.
On review, the Court (Chief Judge Garland and Circuit Judges Srinivasan and Kavanaugh) agreed with the Board’s conclusion that the peer review committee was not a “political subdivision” of the State of Kansas, noting that under the test of NLRB v. Natural Gas Utility District of Hawkins County, 402 U.S. 600, 604 (1971), the committee was neither created directly by the state, so as to constitute a department or administrative arm of the government, nor was it administered by individuals who are responsible to public officials or to the general electorate. However, the Court (Judge Kavanaugh concurring) did not agree that the Weingarten violations could be sustained, principally because of the nature of the peer review committee procedures. The Court stated that, rather than a compulsory in-person interview, employees had the option of appearing, or, in lieu of appearing, filing a written response. “In those circumstances,” the Court explained, “neither nurse was compelled to attend a [c]ommittee hearing so as to trigger a right to union representation under Weingarten.” Judge Kavanaugh agreed, but wrote separately to state the Court had assumed that Weingarten rights would apply to peer review committee interviews, which was a threshold question left open for a future panel to address.
On the confidentiality rule, the Court upheld the Board’s finding as reasonable, consistent with settled precedent, and supported by substantial evidence. Finally, the panel majority held that the Employer’s refusal to provide the requested information was unlawful. Dissenting on the issue, Judge Kavanaugh would have remanded the question to the Board “to re-balance the [Employer]’s confidentiality interest against the [U]nion’s asserted need for the information, in the manner suggested by Member Johnson.”
The Court’s opinion is here (link is external).
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Mondelez Global, LLC (13-CA-170125; JD-65-17) Chicago, IL. Administrative Law Judge Charles J. Muhl issued his decision on August 14, 2017. Charge filed by Bakery, Confectionery, Tobacco Workers & Grain Millers Local Union No. 300, AFL-CIO-CLC.
Anthony & Associates, Inc. (05-CA-153220; JD-66-17) Washington, DC. Administrative Law Judge Michael A. Rosas issued his decision on August 18, 2017. Charge filed by an individual.
Source: NLRB
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