National Labor Relations Board v. Southern Health Corp. D/B/A Corydon Nursing Home

514 F.2d 1121, 89 L.R.R.M. (BNA) 2228, 1975 U.S. App. LEXIS 14843
CourtCourt of Appeals for the Seventh Circuit
DecidedMay 2, 1975
Docket73-2028
StatusPublished
Cited by17 cases

This text of 514 F.2d 1121 (National Labor Relations Board v. Southern Health Corp. D/B/A Corydon Nursing Home) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh 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. Southern Health Corp. D/B/A Corydon Nursing Home, 514 F.2d 1121, 89 L.R.R.M. (BNA) 2228, 1975 U.S. App. LEXIS 14843 (7th Cir. 1975).

Opinions

FAIRCHILD, Chief Judge.

The National Labor Relations Board found that Southern Health Corporation, operator of a nursing home at Corydon, Indiana, refused to bargain with its employees’ certified bargaining agent in violation of Sections 8(a)(5) and (1) of the National Labor Relations Act (29 U.S.C. §§ 158(a)(5) and (a)(1)). The company concedes refusal to bargain but challenges the certification.

On May 19, 1972 a consent election was conducted by the Board. The vote was 12 to 9 in favor of the union, with two challenged ballots. On May 26 the company filed objections to certain pre-[1123]*1123election conduct of the union which allegedly affected the outcome of the bal-' loting. The Regional Director conducted an administrative investigation of the company’s objections and made a report recommending that the objections be overruled. The Board, after considering the company’s exceptions, adopted the Regional Director’s recommendations and certified the union as exclusive bargaining agent. In the complaint proceeding, the general counsel moved for summary judgment on the pleadings, asserting that all matters presented by the company as justification of its refusal to bargain had been previously raised and rejected in the representation proceeding. In response, the company, for the first time, demanded a hearing with respect to the factual issues raised by its objections to the election. The Board granted summary judgment, concluding that “[a]ll issues raised by Respondent in this proceeding were or could have been litigated in the prior representation proceeding, and the Respondent does not offer to adduce at a hearing any newly discovered or previously unavailable evidence, nor does it allege that any special circumstances exist herein which would require the Board to reexamine the decision made in the representation proceeding.” In resisting enforcement the company contends that in the representation proceeding the Board should have denied certification as a matter of law, or at least that the Board should have conducted a hearing into the company challenges.

I.

It is well established that under the statutory scheme of the National Labor Relations Act, the Board is entrusted with the responsibility of conducting elections and of supervising the conduct and actions of the parties therein concerned to insure a free, unfettered exercise of self-determination. See generally, N.L.R.A. Part 9; N.L.R.B. v. A. J. Tower Co., 329 U.S. 324, 328, 67 S.Ct. 324, 91 L.Ed. 322 (1946). This function is essentially administrative in nature, and the courts have, therefore, evidenced reluctance to interfere. “The conduct of representation elections is the very archetype of a purely administrative function, with no quasi about it, concerning which courts should not interfere save for the most glaring discrimination or abuse.” N.L.R.B. v. Olson Bodies, Inc., 420 F.2d 1187, 1189 (2nd Cir. 1969), cert. denied, 401 U.S. 954, 91 S.Ct. 966, 28 L.Ed.2d 237 (1971).

Considerable latitude must be given the Board where an election is challenged, even for substantial misrepresentations. N.L.R.B. v. Mar Salle, Inc., 138 U.S.App.D.C. 135, 425 F.2d 566, 570-571 (1970). The Act does not specifically require post-election examination of such matters. Rather, the Board, as an administrative decision designed to effectuate its primary task of insuring an acceptable democratic labor election process, has determined that flagrant and substantial pre-election misconduct may so impair the integrity of the ballot result that invalidation of the election is necessary. Hollywood Ceramics Co., Inc., 140 N.L.R.B. 221, 223 (1962).

In applying this policy, the Board has emphasized that the election environment itself produces many instances of campaign impropriety which employees frequently ignore or discount. Id. Modine Mfg. Co., 203 N.L.R.B. No. 77, 1973, C.C.H. N.L.R.B. (125,352) p. 32,667, enforced 500 F.2d 914 (8th Cir. •1974). Thus, before resorting to the serious remedy of invalidating an election, with its attendant dangers of delay, administrative over-extension, and frustration of the. goal of self-determination, the Board relies upon its experience and expertise in labor elections to determine, under all of the peculiar circumstances present, “whether the conduct could reasonably be expected to have an impact on the election.” Hollywood Ceramics Co., Inc., supra, 140 N.L.R.B. at 224. See generally, Linn v. Plant Guard Workers, 383 U.S. 53, 60, 86 S.Ct. 657, 15 L.Ed.2d 582 (1965).

The courts have been mindful of the competing considerations present in [1124]*1124such a determination and thus deference is given to the Board’s expert and considered opinion. In reviewing a Board decision in this area “[t]he substantial evidence test enunciated in Universal Camera Corp. v. N.L.R.B., 340 U.S. 474, 71 S.Ct. 456, 95 L.Ed. 456 (1951), has no applicability. Rather, we must defer to the Board’s expertise unless we are prepared to say that the discretion residing in the Board was abused.” Follett Corporation v. N.L.R.B., 397 F.2d 91, 95 (7th Cir. 1968).

II. MISREPRESENTATIONS

a. The Union’s Power to Fine

On May 8, 1972 company president Ragland wrote to the employees urging votes against the union. In the letter he said, among other things, “Even more shocking is the very great power which unions have to fine and discipline their members and make it stick.” He cited examples of fines of employees who went back to work during a strike and of those who crossed a picket line.

On May 17 the organizing committee of the union wrote to the employees challenging as misleading, statements in three of Mr. Ragland’s letters. The letter said in part:

“Mr. Ragland stated in his letter to you of May 8 that the Union fined people for crossing a picket line. What Union was he talking about? It was not this Union because under our Union Constitution we cannot fine anyone. If he tells you that it was this Union, then he is lying again. We are going to bring this mistruth and other lies that have been told to the attention of the National Labor Relations Board (U.S. Government).”

The company, in its objection to certification, presented copies of the constitutions of the international and its local unions, pointing out that there is no express prohibition against fines, and each constitution provides for a disciplinary procedure, the international referring to “fining” as one type of discipline, and the local referring to exacting “an appropriate penalty.” No assertion was made as to the union’s practice in fact with respect to fines for strike breaking or crossing picket lines.

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514 F.2d 1121, 89 L.R.R.M. (BNA) 2228, 1975 U.S. App. LEXIS 14843, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-labor-relations-board-v-southern-health-corp-dba-corydon-ca7-1975.