International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, Uaw v. National Labor Relations Board, Ex-Cell-O Corporation v. National Labor Relations Board

449 F.2d 1046, 145 U.S. App. D.C. 384, 76 L.R.R.M. (BNA) 2753, 1971 U.S. App. LEXIS 11281
CourtCourt of Appeals for the D.C. Circuit
DecidedMarch 19, 1971
Docket24715
StatusPublished
Cited by34 cases

This text of 449 F.2d 1046 (International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, Uaw v. National Labor Relations Board, Ex-Cell-O Corporation 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
International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, Uaw v. National Labor Relations Board, Ex-Cell-O Corporation v. National Labor Relations Board, 449 F.2d 1046, 145 U.S. App. D.C. 384, 76 L.R.R.M. (BNA) 2753, 1971 U.S. App. LEXIS 11281 (D.C. Cir. 1971).

Opinion

449 F.2d 1046

INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE AND AGRICULTURAL IMPLEMENT WORKERS OF AMERICA, UAW, Petitioner,
v.
NATIONAL LABOR RELATIONS BOARD, Respondent.
EX-CELL-O CORPORATION, Petitioner,
v.
NATIONAL LABOR RELATIONS BOARD, Respondent.

No. 24577.

No. 24715.

United States Court of Appeals, District of Columbia Circuit.

Argued December 3, 1970.

Decided March 19, 1971.

Mr. John Silard, Washington, D. C., with whom Messrs. Joseph L. Rauh, Jr., Washington, D. C., and Stephen I. Schlossberg, Detroit, Mich., were on the motion for summary reversal by petitioner in number 24,577.

Mr. Warren M. Davison, Washington, D. C., with whom Mr. Marcel Mallet-Prevost, Assistant General Counsel, was on the motion for temporary relief by respondent in number 24,715, and on respondent's opposition to the motion for summary reversal in number 24,577.

Mr. Stanley R. Strauss, Washington, D. C., with whom Mr. Kenneth C. McGuiness, Washington, D. C., was on petitioner's opposition to the motion for temporary relief in number 24,715.

Before BAZELON, Chief Judge, and LEVENTHAL and MacKINNON, Circuit Judges.

PER CURIAM:

These two cases, consolidated on appeal, concern a National Labor Relations Board [NLRB] order directing Ex-Cell-O Corporation to bargain collectively with the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW).

Having found the Ex-Cell-O plant in Elwood, Indiana to be an appropriate unit for purposes of collective bargaining, the NLRB conducted an election there in October 1964; employees chose the Union as their collective bargaining representative. Ex-Cell-O contested the election in administrative proceedings which included a full trial before a Hearing Officer; the Board ultimately certified the Union as representative in October 1965.1 Ex-Cell-O, seeking to obtain judicial review of the certification, refused to bargain with the Union.2 The Board initiated an unfair labor practice proceeding against Ex-Cell-O,3 and in August 1970 adopted the Trial Examiner's decision of March 1967 ordering Ex-Cell-O to bargain with the Union; however, the Board did not adopt that part of the Examiner's decision granting the Union's request for special compensatory benefits as a "make-whole" remedy for the period when Ex-Cell-O refused to bargain with the Union even after it was certified.4

In case No. 24,577, the Union's petition for review of the NLRB's decision not to award special compensation, the Union has moved for summary reversal, relying on our Tiidee Products — I decision.5 In case No. 24,715 (transferred to us from the Sixth Circuit), Ex-Cell-O seeks to set aside the order directing it to bargain, and the Board — proceeding under § 10(e) of the Act6 — has cross-applied for enforcement of its order against Ex-Cell-O, and in addition, has moved for temporary relief in the form of an order requiring Ex-Cell-O to bargain during the pendency of this litigation. We grant the motion for summary reversal and deny the motion for temporary relief.

The Union's Motion for Summary Reversal in No. 24,577

In Tiidee Products — I, supra note 5, this Court determined that the NLRB has power to award "make-whole" compensation for the period of an unlawful refusal to bargain under § 10(c) of the Act, which requires the Board "to take such affirmative action * * * as will effectuate the policies" of the Act.7 The opinion noted that even after a bargaining representative is certified, an employer may refuse to bargain in order to avoid collective bargaining or to secure judicial review of the certification, and the obligation to bargain collectively may not be finally enforced until an unfair labor practice proceeding results in an order to bargain and an enforcement proceeding in the courts.8 Emphasizing both the crucial importance to the statutory scheme of enforcing the obligation to bargain collectively and the need to avoid encouragement of frivolous litigation before both the Board and the reviewing courts by allowing employers to benefit from delay, this Court found that the "broad command" of § 10(c) authorizes the Board to award unions compensatory relief for harm caused by employers' manifestly unjustified refusals to bargain.

In the Ex-Cell-O case now before us, a divided Board indicated that our Tiidee Products — I decision was unsound, and maintained, contrary to our decision, that it had no power to grant "make-whole" compensation absent an amendment to the Act.9 The Board thought that such an award would compel contractual agreement in contravention of § 8(d),10 constitute an illegal penalty, and involve a measure of compensation too speculative to permit relief.11 Each of these arguments was considered and rejected in Tiidee Products — I.12

Special relief was granted in Tiidee Products — I because the refusal to bargain was so clearly unjustified, based on an attack on the election found to be "palpably without merit."13 This Court recognized that "make-whole" compensation may be inappropriate where the challenge is based on a "debatable question," and emphasized the NLRB's discretionary power to formulate remedies for violations of the Act.14 Tiidee Products — I requires the Board to determine whether an employer's refusal to bargain is a flagrant violation of the Act because its legal objections are frivolous, and if so, whether "make-whole" relief or some other special remedy should be granted.15

In Ex-Cell-O, the NLRB also gave some indication that it was holding in the alternative that Ex-Cell-O's violation was not flagrant — because it was based on debatable questions concerning the certification of the Union — and that "make-whole" relief was therefore inappropriate. This conclusion, however, was apparently based on the Board's assumption that an employer seeking judicial review of an election could never be charged with a flagrant violation, absent "discharge of employees for union activity or other conduct in flagrant disregard of employee rights."16 The clear import of Tiidee Products — I is that an employer's refusal to bargain based on a frivolous challenge to an election is of itself a serious and manifestly unjustified repudiation of the employer's statutory duties and denial of employees' statutory rights to collective bargaining, and that "make-whole" compensation is a proper remedy in such circumstances.

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449 F.2d 1046, 145 U.S. App. D.C. 384, 76 L.R.R.M. (BNA) 2753, 1971 U.S. App. LEXIS 11281, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-union-united-automobile-aerospace-and-agricultural-cadc-1971.