Amalgamated Clothing Workers v. National Labor Relations Board

527 F.2d 803, 174 U.S. App. D.C. 20, 90 L.R.R.M. (BNA) 3258, 1975 U.S. App. LEXIS 11608
CourtCourt of Appeals for the D.C. Circuit
DecidedDecember 8, 1975
DocketNos. 74-1608, 74-1668
StatusPublished
Cited by4 cases

This text of 527 F.2d 803 (Amalgamated Clothing Workers v. National Labor Relations Board) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amalgamated Clothing Workers v. National Labor Relations Board, 527 F.2d 803, 174 U.S. App. D.C. 20, 90 L.R.R.M. (BNA) 3258, 1975 U.S. App. LEXIS 11608 (D.C. Cir. 1975).

Opinions

Opinion for the Court filed by Circuit Judge TAMM.

Opinion filed by Circuit Judge MacKINNON, concurring in part and dissenting in part.

TAMM, Circuit Judge:

This case concerns the enforceability of a bargaining order issued by the National Labor Relations Board against an employer for pre-election unfair labor practices following his refusal to bargain with a union claiming majority status by virtue of authorization cards. This challenge to a NLRB bargaining order is a familiar one despite the Supreme Court’s enforcement of a similar order in NLRB v. Gissel Packing Co., 395 U.S. 575, 89 S.Ct. 1918, 23 L.Ed.2d 547 (1969). We find the facts of this case squarely within the parameters established in Gissel and affirm both the finding of unfair labor practices and the bargaining order.

Jimmy Richard Co., Inc. is a Georgia manufacturer of men’s and boys’ clothing. In April of 1973, Amalgamated Clothing Workers of America, AFL-CIO made a written demand for recognition based on authorization cards signed by a majority of the employees. The demand was refused four days later in a letter claiming the company’s good faith doubt as to the union’s majority status. The union then filed an election petition with the NLRB which was approved on May 9. After the union lost the June 1 election by a vote of 50 to 42, it filed objections alleging that during the two-week period preceding the election the employer had promised a change in vacation scheduling and an additional paid holiday if the union lost the election, had threatened plant closing or moving, and had interrogated employees and solicited withdrawal of the union authorizations.1 After a hearing the Administrative Law Judge (ALJ) concluded that the employer’s threat to close the plant if the union made unreasonable demands, his manner of notifying selected employees about proposed vacation changes, and his unilateral adoption of the vacation changes following the election violated section 8(a)(1) of the National Labor Relations Act, 29 U.S.C. § 158(a)(1) (1970); the ALJ found no merit, however, in the claims of solicitation and interrogation. He further held that the pre-election 8(a)(1) violations, combined with the refusal to accept the union’s continuing demand for recognition, constituted a violation of the section 8(a)(5) duty to bargain. Noting the highly coercive nature of threats of plant closing and the very slight possibility of a fair rerun election, the ALJ recommended that the NLRB issue both a cease and desist order and a bargaining order. The NLRB affirmed and issued the recommended orders. Pursuant to section 10(f) of the National Labor Relations Act, the union has appealed the ALJ’s finding that the employer had not solicited withdrawal of the authorizations; the NLRB has sought enforcement of its order under section 10(e).2 In this consolidated ap[23]*23peal, the employer has challenged both the unfair labor practices findings and the issuance of the bargaining order.

We affirm the NLRB’s adoption of the ALJ’s findings as to 8(a)(1) and 8(a)(5) violations in all respects. The record clearly provides substantial evidence to support the finding that the employer, acting through the plant supervisor, informed selected employees that the vacation changes were “good news” — by inference, a benefit to be enjoyed along with an additional holiday if the union lost the election. I J.A. at 12-15. The record also supports the ALJ’s factual determination that the employer assisted employees’ revocation of union authorization only upon request of the employees and, therefore, did not engage in impermissible solicitation or interrogation. Id. at 5 — 8. These were issues of credibility and, as such, were properly left to the ALJ. We also agree that the speeches and individual conversations threatening possible plant closing or moving were not within the narrow sphere of protected employer speech delineated in Gissel. Recognizing “the economic dependence of the employees on their employers, and the necessary tendency of the former, because of that relationship, to pick up intended implications of the latter that might be more readily dismissed by a more disinterested ear,” 395 U.S. at 617, 89 S.Ct. at 1942, the Court required that any predictions be capable of objective proof of consequences beyond the employer’s control. Id. at 618, 89 S.Ct. 1918. We find in this case, as the Court did in Gissel, that “the Board could reasonably conclude that the intended and understood import of that message was not to predict that unionization would inevitably cause the plant to close but to threaten to throw employees out of work regardless of the economic realities.” Id. at 619, 89 S.Ct. 1918.

Having determined that affirmance of the 8(a)(1) and 8(a)(5) violations is required, we need only resolve whether the Board’s bargaining order is consistent with both its policy favoring certification elections and the bargaining order guidelines established in NLRB v. Gissel Packing Co., supra. We believe that it is.

In Gissel, the Supreme Court upheld a bargaining order issued against General Steel Products, Inc.3 The employer had objected to the validity of the cards, but that issue was resolved against him by the trial examiner. Meanwhile the employer had committed unfair labor practices in the pre-election period. In affirming the bargaining order, the Court noted that even “in less extraordinary cases marked by less pervasive practices,” the Board’s expertise entrusted it, and not the courts, with the responsibility for selecting the appropriate remedy. Id. at 612, 89 S.Ct. at 1940 n.32. The Court enunciated three prerequisites for issuance of a bargaining order where the unfair labor practices are not “outrageous” or “pervasive”: (1) the union at one point had a majority; (2) the employer has committed unfair labor practices; and (3) the possibility of ensuring a fair election by traditional remedies is slight and thus better protected by a bargaining order.4 The extensiveness of [24]*24past employer practices, while not necessarily determinative, is a consideration for the Board in balancing the preference for the election procedure with the need to assure a fair election. Id. at 614, 89 S.Ct. 1918.

In this case, the ALJ found that prior to employee revocation the union had obtained 59 authorizations out of 94 employees. I J.A. at 16. Although 12 of these authorizations were revoked before the April 16 demand for recognition, leaving 47 out of 94, the findings reveal that before the consent election was approved, the union had again obtained a majority, including one card signed on April 14.5 Id. at 17-18.

The employer’s unfair labor practices — coercive threats, promises of benefits, and unilateral changes in employment conditions — occurred after the consent election was approved on May 9 and after the union had obtained majority status. These practices reasonably account for the union’s losing the election by the narrow vote of 50 to 42. See generally NLRB v. Dixisteel Buildings, Inc., 445 F.2d 1260 (8th Cir.1971).

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527 F.2d 803, 174 U.S. App. D.C. 20, 90 L.R.R.M. (BNA) 3258, 1975 U.S. App. LEXIS 11608, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amalgamated-clothing-workers-v-national-labor-relations-board-cadc-1975.