Local 833, UAW-AFL-CIO, International Union, United Automobile, Aircraft & Agricultural Implement Workers v. National Labor Relations Board

300 F.2d 699, 112 U.S. App. D.C. 107, 49 L.R.R.M. (BNA) 2485, 1962 U.S. App. LEXIS 6089
CourtCourt of Appeals for the D.C. Circuit
DecidedJanuary 26, 1962
DocketNos. 15961, 16031, 16182
StatusPublished
Cited by41 cases

This text of 300 F.2d 699 (Local 833, UAW-AFL-CIO, International Union, United Automobile, Aircraft & Agricultural Implement 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
Local 833, UAW-AFL-CIO, International Union, United Automobile, Aircraft & Agricultural Implement Workers v. National Labor Relations Board, 300 F.2d 699, 112 U.S. App. D.C. 107, 49 L.R.R.M. (BNA) 2485, 1962 U.S. App. LEXIS 6089 (D.C. Cir. 1962).

Opinions

BAZELON, Circuit Judge.

These are petitions for review and enforcement of an order of the National Labor Relations Board concerning a strike by Local 833, UAW-AFL-CIO, against the Kohler Company. The strike began on April 5, 1954, and was still unsettled when the Board issued its order on August 26, 1960. The dispute has a long and bitter history — more typical of “a bygone era” — which is set forth in detail in the Board’s decision. Kohler Co., 128 N.L.R.B 1062 (1960). In this, opinion we relate only those facts re^ [701]*701quired to understand the issues we consider.

I. The Board’s Decision and Order

The Board found that a disagreement over contract terms and not Kohler’s alleged refusal to bargain caused the strike, but that it was prolonged by such refusals on and after June 1, 1954. On that date Kohler granted a three-cent wage increase to non-striking employees working under the conditions specified in an expired contract, but failed to make a similar offer to the Union. The Board also found that Kohler subsequently refused to bargain in good faith in the following respects, among others: by unilaterally putting into effect a second wage increase; by discharging striking employees and transferring non-striking employees without notification to or consultation with the Union; and by refusing to furnish wage information pertinent to the negotiations. The Board also determined that Kohler violated § 8(a) (3) and (1) of the Act, 29 U.S.C.A. § 158(a) (1, 3) by discriminatorily treating some employees and unlawfully discharging others because of their participation in strike activities. In addition, the Board found that after June 1, 1954, Kohler interfered with, restrained, and coerced its employees in the exercise of their right to join labor unions and bargain collectively by engaging in surveillance and anti-union espionage, evicting certain strikers from Company-owned dwellings, and other conduct violating § 8(a) (1) of the Act.

Having concluded that Kohler’s unfair labor practices on and after June 1, 1954, converted what the Board thought had been an economic strike into an unfair labor practice strike, the Board issued a remedial order directing the Company, inter alia,, to reinstate strikers replaced after the June 1 unilateral wage increase,1 2excepting, however, employees discharged on March 1, 1955, for misconduct in connection with the strike.

II. Kohler’s Petition for Eeview in No. 16182

In No. 16182 Kohler seeks review of the Board’s adverse determinations. We think they are amply supported by the record considered as a whole and that Kohler’s attack must fail.3 Since we fully adopt the Board’s analysis of the evidence on these matters, further discussion would serve no useful purpose.

III. The Union’s Petition for Eeview in No. 15961

In No. 15961 the Union challenges the Board’s refusal to reinstate seventy-seven employees discharged for misconduct. It alleges that the Board failed to balance that misconduct against the Company’s unfair labor practices. This balancing, it contends, is required by the statutory command that the Board’s remedy “effectuate the policies of the [Act] * * 3 National Labor Relations Board v. Thayer Co., 213 F.2d 748 (1st Cir.), cert. denied, 348 U.S. 883, 75 S.Ct. 123, 99 L.Ed. 694 (1954) 4 The Union also contends that the Board should have found that [702]*702Kohler failed, both in form and substance, to bargain in good faith in the unsuccessful negotiations which culminated in the 1954 strike and that the walkout was therefore an unfair labor practice strike from its inception on April 5, 1954. In the absence of such a finding, the Board ordered reinstatement only of employees whose jobs were filled after June 1, 1954. Had it found that Kohler’s unfair labor practices caused the walkout on April 5, it might have ordered reinstatement of all strikers replaced by non-strikers at any time during the dispute.5 Moreover, if the Thayer doctrine is valid, the Board should have balanced Kohler’s unfair labor practices against the discharged strikers’ misconduct whether it occurred either before or after June 1, 1954.6

A. The Discharges for Misconduct.

We first set forth the facts relevant to the Union’s request that the Board be directed to reconsider its decision not to reinstate seventy-seven strikers discharged for misconduct. Their misconduct occurred in connection with three series of incidents.

First, forty-four discharges were based on participation in “belly-to-back” mass picketing ranging from presence on the picket line to a physical assault upon a non-striker. The Board found that from April 5 through May 28 this picketing prevented any person who did not have a Union pass from entering Kohler’s plants. The second series of incidents involved demonstrations by large, jeering crowds outside the homes of non-strikers during the month of August, 1954. Some strikers who actively participated in the demonstrations and others who were merely present in the crowds were discharged. The third series of incidents took place near Kohler’s employment office in December 1954 and January 1955 when a group of Union pickets hindered applicants from entering by blocking, pushing, and shoving some of them and by forcing others to walk around the pickets. Kohler discharged the participants.7 The last two series of incidents accounted for twenty-one discharges.8 The remaining twelve dischargees were members of the Union’s strike committee which the Board found instigated some of the misconduct.

The trial examiner found that some of these employees had been discharged for activity which did not constitute misconduct or which Kohler had condoned. Accordingly, he recommended their reinstatement. But the Board reversed the examiner’s findings. We put aside the Union’s attack upon the Board’s reasons for reversal,9 and turn to the Union’s contention that, in any event, we should direct the Board to reconsider the reinstatement issue in light of the Thayer doctrine.

B. The Application of the Thayer Doctrine.

Thayer holds that where an employer who has committed unfair labor practices discharges employees for unprotected acts of misconduct, the Board must consider both the seriousness of the employer’s unlawful acts and the seriousness of the employees’ misconduct in determining whether reinstatement would [703]*703effectuate the policies of the Act.10 Those policies inevitably come into conflict when both labor and management are at fault. To hold that employee “misconduct” automatically precludes compulsory reinstatement ignores two considerations which we think important. First, the employer’s antecedent unfair labor practices may have been so blatant that they provoked employees to resort to unprotected action.11 Second, reinstatement is the only sanction which prevents an employer from benefiting from his unfair labor practices through discharges which may weaken or destroy a union. In the Matter of H. N. Thayer Co., 115 N.L.R.B. 1591, 1605-06 (1956) (dissenting opinion) .

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Bluebook (online)
300 F.2d 699, 112 U.S. App. D.C. 107, 49 L.R.R.M. (BNA) 2485, 1962 U.S. App. LEXIS 6089, Counsel Stack Legal Research, https://law.counselstack.com/opinion/local-833-uaw-afl-cio-international-union-united-automobile-aircraft-cadc-1962.