Overstreet v. AJNC Industries LLC

CourtDistrict Court, D. Nevada
DecidedJuly 19, 2021
Docket2:21-cv-00730
StatusUnknown

This text of Overstreet v. AJNC Industries LLC (Overstreet v. AJNC Industries LLC) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Overstreet v. AJNC Industries LLC, (D. Nev. 2021).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 REGIONAL DIRECTOR CORNELE A. ) 4 OVERSTREET, ) ) Case No.: 2:21-cv-00730-GMN-EJY 5 Petitioner, ) vs. ) ORDER 6 ) 7 AJNC INDUTRIES LLC d/b/a CLARK ) WELDING & FABRICATING ) 8 ) Defendant. ) 9 10 Pending before the Court is Petitioner Cornele A. Overstreet’s (“Petitioner’s” or “the 11 Regional Director’s”) Petition for Temporary Injunction, (ECF No. 1), which he brings in his 12 capacity as the Regional Director of the National Labor Relations Board (“NLRB”). 13 Respondent AJNC Industries LLC d/b/a Clark Welding & Fabricating (“CWF”) filed a 14 Response, (ECF No. 6), and Petitioner filed a Reply, (ECF No. 8). 15 Also pending before the Court is Petitioner’s Motion to Try the Petition on the Basis of 16 the Administrative Record, Affidavits, and Documentary Evidence, (ECF No. 3). CWF filed a 17 Response, (ECF No. 7), and Petitioner filed a Reply, (ECF No. 9).1 18 Also pending before the Court is Petitioner’s Motion for Leave to file Excess Pages, 19 (ECF No. 4). CWF did not file a Response.2 20 For the reasons discussed below, the Court GRANTS the Motions to Try the Petition on 21 the Basis of the Administrative Record and for Leave to File Excess pages. The Court 22 nevertheless DENIES the Petition. 23 24 1 The Court finds the Petition suitable for adjudication without an evidentiary hearing and therefore grants the Motion. 25 2 The Court grants the Motion as unopposed pursuant to LR 7-2(d). 1 I. BACKGROUND 2 This case arises from CWF’s allegedly unlawful response to a union organizing 3 campaign that began in July of 2020. (See generally Memorandum in Support of Pet. Temp. 4 Inj. (“Pet. Temp. Inj.”), ECF No. 1-1). CWF provides HVAC services including boiler, 5 installation, and fabrication in and around Las Vegas, Nevada. (Apr. 6 Admin. Hearing Tr. 6 33:1–20, PX 12, ECF No. 1-7). CWF has approximately 24 employees, 14 of which perform 7 boiler and other HVAC services. (Id. 480:8–10); (Aff. Austin Peck Dated Jan. 15, 2021 (“Jan. 8 Peck Aff.”) ¶ 10, PX 6, ECF No. 1-5). 9 In July of 2020, Austin Peck (“Peck”) an organizer for 5 States Pipe Trades Association 10 (“the Union”) approached two CWF employees, Corey Beran (“Beran”) and Craig Chapman 11 (“Chapman”), at a job site during their lunch break. (Jan. Peck Aff. ¶ 2, PX 6). Peck engaged 12 the employees in discussion about what the Union could accomplish for CWF’s employees, 13 provided the employees with Union literature, and gave the employees his phone number. (Id.). 14 Peck then began communicating with Beran and Chapman on a regular basis. (Id.); (See also 15 Aff. Austin Peck Dated Apr. 6, 2021 (“Apr. Peck Aff.”) at 8–10, PX 8, ECF No. 1-6). After 16 meeting Beran and Chapman, other CWF employees including Anthony Scalzo (“Scalzo”) and 17 Tyler Christenson (“Christenson”) reached out to Peck regarding their interest in the union 18 campaign. (Jan. Peck Aff. ¶ 3, PX 6). 19 On September 4, 2020, Scalzo and Peck met at the Union’s headquarters, where Scalzo 20 signed a union authorization card. (Id. ¶ 4). Christenson and Peck met at a restaurant the 21 following day, and Christenson signed an authorization card at the meeting. (Id.). As the 22 support for the Union grew among CWF’s employees, Peck started regularly keeping in contact

23 with 10 employees, including Beran, Chapman, Rory Johnson (“Johnson”), Kevin Juarez 24 (“Juarez”), Joe Childress, Matt Gonsalez, and Parker Elias. (Id. ¶¶ 5–7). On September 8, Peck 25 received an authorization card from Juarez. (Id.). Around the same time, Chapman informed 1 Scalzo he was ready to sign an authorization card. (Apr. 6 Admin. Hearing Tr. 394:13–21, 2 PX 12). 3 Meanwhile, as the Union began gaining support, employee Michael Ralls (“Ralls”) was 4 on vacation from September 2–7. (Aff. Michael Ralls (“Ralls Aff.”) ¶ 5, PX 5, ECF No. 1-5). 5 Christenson called Ralls about the Union campaign during his vacation, and Ralls expressed 6 interest in the campaign and asked for Peck’s information. (Id.). When Ralls returned, he 7 discovered that he was not scheduled to work for the week of September 7 despite previously 8 being told to return no later than September 7 because he would be needed to work on a large 9 project in Henderson. (Id. ¶¶ 5, 8). On September 8, Ralls met with Peck and signed an 10 authorization card. (Id. ¶¶ 9–10). After signing the card, Ralls contacted HVAC Supervisor 11 Nilson to ask why he was not on the schedule for that week, and when Nilson could not provide 12 an explanation, Ralls said he disagreed with the decision. (Id. ¶ 11). Ralls believes he was the 13 only employee whose hours had been reduced during the week of September 7. (Apr. 6 Admin. 14 Hearing Tr. 326:25–327:12, PX 12). 15 On September 9, Peck learned that employee Will Perks had informed CWF’s owner- 16 managers, Coltin Clark (“Coltin”) and Austin Clark (“Austin”), (collectively, “the Clarks”), 17 about the Union campaign. (Jan. Peck Aff. ¶ 8, PX 6). On the same day, CWF sent its 18 employees a group text message informing them of an all-staff meeting on September 10. (Id. ¶ 19 9). While the meeting initially focused on complaints regarding cleanliness of work sites, the 20 Clarks pivoted to “[t]he main reason we’re doing this meeting,” discussing the Union. (Tr. 21 Meeting Recording 5:11–13, PX 10, ECF No. 1-7). The Clarks asked questions regarding the 22 extent of the Union campaign, how the employees had been contacted, the effect unionizing

23 could have on the availability of work, and the Union literature that had been distributed to 24 employees. (Id. 5:12–7:4). After the September 10 meeting, Peck stopped receiving messages 25 1 from most of the employees with whom he had previously been in regular contact, and the 2 Union’s momentum stalled. (Jan. Peck Aff. ¶¶ 11–12, PX 6). 3 After continuing attempts to push the Union campaign forward, Peck and another 4 organizer met with the Clarks to discuss whether the Clarks would prefer to avoid the expense 5 of an anti-union campaign and instead recognize the Union as its employees’ collective 6 bargaining representative. (Aff. Austin Clark ¶¶ 2–3, PX 11, ECF No. 1-7). The Clarks 7 declined. (See id.). Later that same day, when Ralls arrived to work in CWF’s shop, Coltin 8 ordered Ralls to his office. (Ralls Aff. ¶ 18, PX 5). When Ralls arrived, he was confronted by 9 the Clarks and Nilson where he was told he would be laid off because work had slowed down, 10 and he would be rehired when work picked up again. (Id.). 11 After the Union campaign fizzled to a stop, an NLRB petition was filed. The NLRB 12 action alleges that CWF responded to the union organizing campaign by engaging in unfair 13 labor practices prohibited under the National Labor Relations Act, 29 U.S.C. §§ 151, et seq. 14 (“NLRA”). Petitioner now seeks a temporary injunction while the NLRB adjudicates the 15 administrative action against CWF. 16 II. LEGAL STANDARD 17 The NLRA regulates relations between “private sector employers, labor unions, and 18 employees.” See Chamber of Commerce of the United States v. NLRB, 721 F.3d 152, 154 (4th 19 Cir. 2013). When enacting the NLRA, Congress intended to “restor[e] equality of bargaining 20 power” between employees and employers by, “encouraging the practice and procedure of 21 collective bargaining and by protecting the exercise by workers of full freedom of association, 22 self-organization, and designation of representatives of their own choosing, for the purpose of

23 negotiating the terms and conditions of their employment.” 29 U.S.C. § 151.

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