National Labor Relations Board v. Kohler Company

351 F.2d 798, 122 U.S. App. D.C. 101, 60 L.R.R.M. (BNA) 2049, 1965 U.S. App. LEXIS 4551
CourtCourt of Appeals for the D.C. Circuit
DecidedSeptember 2, 1965
Docket16031
StatusPublished
Cited by8 cases

This text of 351 F.2d 798 (National Labor Relations Board v. Kohler Company) 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
National Labor Relations Board v. Kohler Company, 351 F.2d 798, 122 U.S. App. D.C. 101, 60 L.R.R.M. (BNA) 2049, 1965 U.S. App. LEXIS 4551 (D.C. Cir. 1965).

Opinion

BAZELON, Chief Judge.

These contempt proceedings are the latest round of a controversy which erupted over eleven years ago when the Kohler strike began. Despite repeated resort to the National Labor Relations Board and the courts, 1 the controversy *801 shows no signs of abating. This is an extra-inning game, even by modern judicial standards. 2 Unless the parties step out of character and achieve a compromise, it appears that many innings lie ahead.

The issues here have their roots in a Board order of August 26, 1960. That order, inter alia, required the Kohler Company to offer reinstatement upon application to the great majority of its striking employees, and to dismiss, if necessary, their replacements. Failure to make such an offer was to entitle the employee to back pay, beginning five days after his application and continuing until an offer was made. 3 Immediately after entry of the Board’s order, Kohler offered reinstatement to certain of the strikers for whom application had been made. Despite repeated advice from the Board during compliance proceedings, first formally tendered in April 1961, Kohler insisted it had thus fully complied with the reinstatement provisions. On March 1, 1962, we enforced the Board’s order without change. 4 In July 1963, the Board asked us to hold Kohler in contempt of our decree. We -referred the issues to a special master. He has filed findings of fact and conclusions of law, supplemented by a full and learned opinion; he concludes that Kohler has violated our decree. Our present task is to review these findings and conclusions.

As will appear, we think Kohler has failed in several respects to comply with the Board’s reinstatement decree, as we enforced it. However, the Master did not attempt to ascertain which employees were wrongfully denied reinstatement by Kohler but stated conclusions as to broad classes of employees. We think we should not enter a contempt order before we know exactly whom Kohler should have reinstated. Accordingly we remand to the Master, under such guides as will appear, for identification of these individuals. The Master’s findings, unless clearly erroneous, will then furnish the basis for any adjudication of contempt.

That order of adjudication will require Kohler to offer reinstatement to the identified employees and provide for allocation of costs, incentives to speedy action and other such matters as we deem appropriate. 5 This probably will not end the proceedings, however. There will be persons who, although wrongfully denied reinstatement, are now entitled at most to limited back pay, death benefits or other relief, because of intervening events precluding reinstatement. When reinstatement is offered, the amount of back pay must also be determined. These questions are to be determined by the Board, for they are within its special competence. N. L. R. B. v. New York Merchandise Co., 134 F.2d 949 (2d Cir. 1943) (per L. Hand, J.).; Wallace Corp. v. N. L. R. B., 159 F.2d 952 (4th Cir. 1947); Note, The Role of Contempt Proceedings In Enforcing Orders of the NLRB, 54 Colum.-L.Rev. 603 (1954). We anticipate postponing consideration whether Kohler has purged itself of con *802 tempt until the Board’s determinations of these questions are final. 6

I. Releasees and Retirees

We first consider whether two groups of strikers — “releasees” and “retirees”— were “striking employees” when Kohler refused their applications for reinstatement at the end of the strike and were therefore entitled to reinstatement.

A. Releasees

The releasees here involved are 82 of the 133 strikers who secured formal releases from employment with Kohler prior to the strike’s end. These releases were evidence by printed cards, prominently headed “Release from Employment,” and signed by the employee as well as Kohler’s representatives. Kohler did not request any employee to sign a release, even if he took interim employment. It listed all strikers as employees unless and until they applied for release. Thus, Kohler argues, an employee’s acceptance of a release was an unequivocal act of resignation, and reinstatement need not have been offered. The Board contends that the 82 strikers it has identified executed the releases under economic compulsion, since they needed work during the strike and prospective employers required releases. It offered to show that the named workers had not intended to give up employment at Kohler and, in at least some cases, had notified Kohler of.that fact, either at the time of seeking release or by personally seeking .reinstatement when the strike ended.

The Master exonerated Kohler in regard to the releasees. He found that the releasees were “estopped from asserting that they did not, on obtaining the release, intend to permanently abandon their employment with the Company.” He grounded this conclusion in broad equitable principles. He said it was plain that “the individuals who procured a release * * * knew what they were doing.” Even though other employers required the releases, he thought there was an “element of deception” involved in the workers’ professed intent to remain “Kohler strikers,” entitled to reinstatement. Such deception, he said, is “abhorrent to American principles of justice,” and should not he condoned by a reinstatement order. An added consideration, he stated, was that proof of worker intent, if accepted as a standard for deciding the reinstatement issue, was too uncertain at this late date, and would put the Company to an unfair disadvantage.

We think the releases did not operate as an estoppel to reinstatement. The Master recognized that “the fashioning of orders to effectuate the policies of the act is primarily the function of the Board.” However, he gave no credence to Board cases holding that employees who had signed releases were not thereby conclusively deprived of any reinstatement right, but that intent to resign was in every case a question of fact. 7 Supreme Court authority confirms the Board’s central role in the definition of “employee,” N. L. R. B. v. Hearst Publications, 322 U.S. 111, 64 S.Ct. 851, 88 L.Ed. 1170 (1944), and the Board’s power to order reinstatement of employees who had found other employment, if to do so would effectuate the remedial .policies of the Act, Phelps Dodge Corp. v N. L. R. B., 313 U.S. 177, 61 S.Ct. 845, 85 L.Ed. 1271 (1941). No one doubts that the Board meant to include releasees as “striking employees” under the reinstatement order unless they had in fact abandoned the strike.

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351 F.2d 798, 122 U.S. App. D.C. 101, 60 L.R.R.M. (BNA) 2049, 1965 U.S. App. LEXIS 4551, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-labor-relations-board-v-kohler-company-cadc-1965.