Radovich v. Agricultural Labor Relations Board

72 Cal. App. 3d 36, 140 Cal. Rptr. 24, 96 L.R.R.M. (BNA) 3034, 1977 Cal. App. LEXIS 1687
CourtCalifornia Court of Appeal
DecidedJuly 27, 1977
DocketDocket Nos. 3073, 3087
StatusPublished
Cited by18 cases

This text of 72 Cal. App. 3d 36 (Radovich v. Agricultural Labor Relations Board) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Radovich v. Agricultural Labor Relations Board, 72 Cal. App. 3d 36, 140 Cal. Rptr. 24, 96 L.R.R.M. (BNA) 3034, 1977 Cal. App. LEXIS 1687 (Cal. Ct. App. 1977).

Opinions

Opinion

HOPPER, J.

Appellants contend: (1) That the superior court has jurisdiction under Code of Civil Procedure section 1094.5 to review the Board’s certification orders. (2) That although the court may not have jurisdiction in all cases to review certification orders, such jurisdiction exists in the present cases due to the exception set forth in Leedom v. Kyne (1958) 358 U.S. 184 [3 L.Ed.2d 210, 79 S.Ct. 180].

For the same reasons set out in Nishikawa Farms, Inc. v. Mahony (1977) 66 Cal.App.3d 781 [136 Cal.Rptr. 233], we hold the first contention to be without merit. We therefore proceed to discuss the second contention.

In 5 Civil 3073 the petition alleged that on September 8, 1975, real party in interest United Farm Workers of America, AFL-CIO (hereinafter UFW or real party) filed with respondent Board a petition to be certified as the collective bargaining agent of appellant Radovich’s agricultural employees. Subsequently the Western Conference of Teamsters, Agricultural Division, filed a petition to intervene in the election. An election was held, resulting in 83 votes for real party, 46 votes for no union, 17 votes for the Teamsters, 2 unresolved challenges, and 1 void [40]*40ballot. Appellant thereupon filed objections to conduct which it alleged affected the election. On October 21, 1975, the Board notified appellant that certain of its objections were being dismissed without hearing. These objections related to the following issues:

“(i) whether the UFW made a proper showing of interest in support of its Petition, as required by Section 1156.3(a) of the Act;
“(ü) whether the ALRB properly utilized symbols on the election ballot and whether the use of symbols on the ballot confused or otherwise misled voters;
“(iii) whether the failure of the ALRB to provide ‘Notices of Election’ until approximately 1:00 p.m. the day before the election resulted in inadequate notice to eligible voters and, consequently, disenfranchised many eligible voters;
“(iv) whether the failure of the ALRB to provide a Sample Ballot with the Notice of Election resulted in the voters being unnecessarily confused at the time of the election by the choices on the ballot;
“(v) whether the UFW’s failure to provide a list of election observers at the pre-election conference prejudiced Petitioner and improperly affected the results of the election.”

Respondent directed that a hearing be held on appellant’s other objections. By a decision issued January 20, 1976, respondent rejected appellant’s contentions and ordered real party certified as bargaining agent for appellant’s employees. The Board found:

“(i) that statements prior to the election by UFW agents to various of Petitioner’s employees, to the effect that there would be no hiring hall if the UFW won the election, did not warrant setting aside the election;
“(ii) that statements prior to the election by UFW agents to various of Petitioner’s employees, to the effect that there would be no dues charged for one year if the UFW won the election, did not warrant setting aside the election;
“(iii) that the offer of free medical care to one of Petitioner’s employees by UFW agents prior to the election did not warrant setting aside the election;
[41]*41“(iv) that the promise by UFW agents of a party for Petitioner’s employees if the UFW won the election did not warrant setting aside the election;
“(v) that threatening statements made prior to the election by UFW agents to certain of Petitioner’s employees in order to coerce support for the UFW did not warrant setting aside the election.”

Appellant’s petition alleged that respondent abused its discretion in making these findings, and that it also denied appellant the right to a fair trial in failing to hold a hearing on appellant’s other objections listed above.

In 5 Civil 3087 the petition alleged that on September 8, 1975, the UFW filed with respondent a petition to be certified as the collective bargaining agent of appellant Cesare and Sons’ agricultural employees. An election was held, resulting in 13 votes for the UFW and 10 votes for no union. Appellant thereupon filed objections to conduct which it alleged affected the election. On October 3, 1975, the Board notified appellant that certain of its objections were being dismissed without hearing. These objections related to the following issues:

“(i) whether the UFW made a proper showing of interest in support of its Petition, as required by Section 1156.3(a) of the Act;
“(ii) whether the ALRB properly utilized symbols on the election ballot and whether the use of symbols on the ballot confused or otherwise misled voters;
“(iii) whether the failure of the ALRB to provide a Sample Ballot with the Notice of Election resulted in the voters being unnecessarily confused at the time of the election by the choices on the ballot.”

Respondent directed that a hearing be held on appellant’s other objections. By a decision issued January 8, 1976, respondent rejected appellant’s contentions and ordered real party certified as bargaining agent for appellant’s employees. The Board found:

“(i) that the failure of the ALRB to conduct the election within seven days of the filing of the Petition, as expressly mandated by Section 1156.3(a) of the Act, did not warrant setting aside the election;
[42]*42“(ii) that the closing of the polls 15 to 30 minutes earlier than scheduled did not warrant setting aside the election;
“(iii) that a statement by UFW agents to several of Petitioner’s employees on the day before the election, to the effect that if the UFW won the election, the employees could get a reelection within 60 days if they were unhappy with the UFW or any contract it negotiated, did not warrant setting aside the election.”

Appellant’s petition alleged that respondent abused its discretion in making these findings, and that it also denied appellant the right to a fair trial in failing to hold a hearing on appellant’s other objections listed above.

Appellants argue that portions of their petitions fall within the exception to the rule that a certification order may not be directly challenged, carved out by Leedom v. Kyne, supra, 358 U.S. 184. In Kyne,

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Bluebook (online)
72 Cal. App. 3d 36, 140 Cal. Rptr. 24, 96 L.R.R.M. (BNA) 3034, 1977 Cal. App. LEXIS 1687, Counsel Stack Legal Research, https://law.counselstack.com/opinion/radovich-v-agricultural-labor-relations-board-calctapp-1977.