Us Airways, Inc. v. National Mediation Board and Communications Workers of America, Afl-Cio

177 F.3d 985, 336 U.S. App. D.C. 152, 161 L.R.R.M. (BNA) 2419, 1999 U.S. App. LEXIS 10888, 1999 WL 335366
CourtCourt of Appeals for the D.C. Circuit
DecidedMay 28, 1999
Docket98-5435
StatusPublished
Cited by13 cases

This text of 177 F.3d 985 (Us Airways, Inc. v. National Mediation Board and Communications Workers of America, Afl-Cio) 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
Us Airways, Inc. v. National Mediation Board and Communications Workers of America, Afl-Cio, 177 F.3d 985, 336 U.S. App. D.C. 152, 161 L.R.R.M. (BNA) 2419, 1999 U.S. App. LEXIS 10888, 1999 WL 335366 (D.C. Cir. 1999).

Opinion

Opinion for the Court filed by Circuit Judge SILBERMAN.

*987 SILBERMAN, Circuit Judge:

The National Mediation Board (NMB) found that U.S. Airways had interfered with its employees’ free choice in a union representation election, and issued an order setting aside the results of that election (which the union had lost) and prescribing a re-run election (which the union won). US Airways challenged the Board’s order in the district court on First Amendment grounds, requesting that the results of the re-run election be set aside, but was rebuffed. We reverse.

I.

The Communications Workers of America (CWA) failed in the first election to garner the votes necessary to represent the passenger service employees of U.S. Airways. The union saw its defeat as the product of a coercive anti-union campaign waged by the carrier’s management leading up to, and during, the representation election. Pursuant to § 2, Ninth of the Railway Labor Act, the union requested that the Board “investigate” the “representation dispute” and “utilize any ... appropriate method of ascertaining the names of [the employees’] duly designated and authorized representatives in such manner as shall insure the choice of representatives by the employees without interference, influence, or coercion exercised by the carrier.” 45 U.S.C. § 152, Ninth.

No one disputes the underlying facts found by the Board in its investigation. For some time prior to the representation election,-an institution known as the “employee roundtable” was a key feature of management’s relationship with the several categories of non-represented passenger service employees. The roundtables, while focusing on operational and other issues in their periodic meetings, also provided a forum for occasional discussion and alteration of U.S. Airways’ employment policies. The impact has been real. Modifications to the carrier’s rules governing vacation scheduling, supervisors’ disciplinary authority, and overtime were only a few of the changes made from 1991-95.

In early 1996, a new management team announced the formation of a company-wide “System Roundtable,” an umbrella entity unifying the existing roundtables that would continue, in the words of one executive officer, to provide a forum for “issues affecting employees.” The System Roundtable continued the tradition of its constituent bodies, implementing changes to the carrier’s policies governing tardiness and trading of shifts among employees, and also delegated to several “task forces” the responsibility to study other policies. The most notable of these task forces was assigned the job of proposing changes to the carrier’s apparently widely despised policy governing paid days off for vacation and sick days.

Between the Board’s authorization of the election in November 1996 and the ballot count on January 30, 1997, U.S. Airways’ management highlighted the above described employment policy changes and the potential for future progress on the matters under study by the task forces. In informational newsletters, telephone hotlines, and meetings, management communicated to the employees that the informal management-employee relationship embodied in the roundtables was inconsistent with union representation: “Electing CWA would force the company to eliminate face-to-face policy making between management and employees at a time when we are beginning to make real progress. Labor laws require employees to deal exclusively with the union on issues of employment policy.”

After reviewing these facts, the Board’s order set forth five “initial standards” viewed as indicative of a carrier’s interference with employee freedom of choice in the context of a workplace in which roundtables (also called employee committees) are present.

1) The establishment of a committee at any time after the carrier becomes aware of a labor organization’s organizing efforts;
*988 2) A material change, or a carrier representation of such a change during the critical period in the purpose or activities of a pre-existing committee;
3) The use of a pre-existing committee to expand employee benefits during the critical period (the continuation of existing benefits is a prerequisite of a fair election);
4) Carrier campaigns which indicate a pre-existing committee is, or should be, a substitute for the collective bargaining representative;
5) Carrier campaigns which indicate that the certification of a labor organization as the representative of the employees will lead to the termination of a preexisting committee.

US Airways, 24 N.M.B. 354, 385-86 (1997). The Board determined that the carrier’s activities ran afoul of each of these five factors: the carrier had established a new roundtable during the critical period; represented to the employees that pre-exist-ing committees had been materially changed so as better to address employment practices; used the roundtables to accomplish the recent changes in attendance and shift-trading policies and the creation of the task forces; portrayed the roundtables as an alternative to union representation; and predicted that the election of the union would result in the elimination of the roundtable process. See id. at 388. The Board concluded that “[biased upon the totality of the circumstances in this case, ... the laboratory conditions required for a fair election were tainted.” Id. at 393.

The Board ordered a re-run election, making clear that “[t]he Carrier is not permitted to influence, interfere [with] or coerce employees in any manner ... in the upcoming election.” Id. at 396. 1 The carrier, after failing to persuade the Board to stay its order pending a motion for reconsideration, filed a complaint in district court, along with an application for a temporary restraining order barring enforcement of the Board’s order. Relying in part on the Board’s representation at the TRO hearing that “[i]f the election goes forward, and then a decision is issued by the court that the board’s decision is invalid, the election will be null and void,” the district court denied the application. See U.S. Airways, Inc. v. NMB, Civ. Act. No. 97-1508, Mem. Order at 3 (D.D.C. July 3, 1997) (“If at some point, the provisions of that Order are held to violate either the statute or the Constitution, the election will be set aside.”).

US Airways, its request for a TRO denied, complied with the Board’s order. The carrier understood the order’s fourth and fifth factors to bar it from advocating the roundtables as an alternative to union representation and from predicting that election of the union would result in the disbanding of the roundtables. So U.S. Airways’ management remained silent on these matters. The union won the re-run election by a slim margin: the ballot count on September 29, 1997, revealed that of the 8,772 eligible voters, 4,773 — or roughly 54% — cast ballots in favor of CWA. The NMB soon thereafter certified CWA as the bargaining representative for the carrier’s passenger service employees.

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177 F.3d 985, 336 U.S. App. D.C. 152, 161 L.R.R.M. (BNA) 2419, 1999 U.S. App. LEXIS 10888, 1999 WL 335366, Counsel Stack Legal Research, https://law.counselstack.com/opinion/us-airways-inc-v-national-mediation-board-and-communications-workers-of-cadc-1999.