NOTICE:  This opinion is subject to formal revision before publication in the bound volumes of NLRB decisions.  Readers are requested to notify the Executive Secretary, National Labor Relations Board, Washington, D.C.  20570, of any typographical or other formal errors so that corrections can be included in the bound volumes.

Gruma Corporation d/b/a Mission Foods and United Food and Commercial Workers International Union Local 99, CLC.  Cases 28–CA–17946, 28–CA–18056–1, 28–CA–18112, 28–CA–18112–2, 28–CA–19076, and 28–CA–20202

July 27, 2007

DECISION AND ORDER

By Chairman Battista and Members Schaumber
and Walsh

On March 29, 2006, Administrative Law Judge Albert A. Metz issued the attached decision.  The Respondent filed exceptions and a supporting brief, the General Counsel filed an answering brief, and the Respondent filed a reply brief.  The General Counsel filed cross-exceptions and a supporting brief, the Respondent filed an answering brief, and the General Counsel filed a reply brief.

The National Labor Relations Board has delegated its authority in this proceeding to a three-member panel. 

The Board has considered the decision and the record in light of the exceptions, cross-exceptions, and briefs and has decided to affirm the judge’s rulings, findings,[1] and conclusions as modified and to adopt the recommended Order as modified and set forth in full below.[2]

i. introduction

This case arose in the wake of an organizing campaign and representation election among the Respondent’s employees at its Tempe, Arizona food manufacturing facility in 2001.  In 2004, the Board certified the Union as the employees’ exclusive collective-bargaining representative.  The complaint alleges, and the judge found, that the Respondent committed various unfair labor practices during the 2001 to 2004 time period.    

Specifically, the judge found, and we agree for the reasons set forth in his decision, that the Respondent violated Section 8(a)(5) and (1) of the Act by taking the following actions without giving the Union notice and an opportunity to bargain: (i) eliminating a bargaining unit position from the sanitation department; (ii) transferring employee Michaela Burgara from the sanitation department to another department; (iii) subcontracting the sanitation department work; and (iv) eliminating its employee-of-the-quarter award.  We also agree with the judge’s findings that the Respondent violated Section 8(a)(5) and (1) by unilaterally changing its method for determining whether to grant an annual wage increase and by unilaterally failing to grant a wage increase in 2002, but we clarify the judge’s rationale.[3]  Similarly, although we agree with the judge’s dismissal of the complaint allegations that the Respondent unlawfully suspended and discharged employee Ramon Marquez, we do so only for the reasons discussed below.

ii. the failure to grant a wage increase
 in 2002

Beginning no later than 1998, the Respondent maintained a practice of granting employees annual wage increases during the first quarter of every calendar year.  According to the Respondent’s employee handbook, an employee’s total wage increase consisted of any combination of three parts: (1) a merit increase; (2) a “structural scale increase,” based on the Respondent’s assessment of the local job market; and (3) a “step” increase, i.e., a job promotion.  The Respondent determined the amount of the structural scale increase by conducting a telephone survey of other area companies to assess wage levels in the local market. 

In September 2001, 1 month after winning the representation election, the Union wrote to the Respondent, insisting that any wage “increases be implemented in the normal course of business” and that the Union “be given advanced notice of and an opportunity to bargain regarding any such [wage] increases.”  Notwithstanding the Union’s request, the Respondent, without giving the Union notice or an opportunity to bargain, unilaterally decided that no structural increases would be given in 2002. 

The Respondent also unilaterally changed the methodology it used for determining whether to grant employees a structural increase.  First, in place of the local market survey, the Respondent used a survey that included employers throughout the State of Arizona.  Second, the Respondent did not conduct the wage survey until October, although its past practice had been to conduct the survey during the first quarter of the year.  Third, the Respondent considered not only the results of the wage survey, but also its recruitment and retention needs.  There is no evidence that those factors had been considered prior to 2002. 

In analyzing whether the Respondent’s conduct violated Section 8(a)(5) and (1) of the Act, the judge applied the multifactor analysis set forth in Dynatron/Bondo Corp.,[4] and found that the Respondent had an established practice of granting first-quarter “merit” increases to employees.  The judge further found that, given this practice, the Respondent had an obligation to bargain with the Union before deciding not to grant a “merit” wage increase in 2002, and that by failing to do so, the Respondent violated Section 8(a)(5) and (1) of the Act.  The judge also found that the Respondent violated Section 8(a)(5) and (1) by unilaterally changing its method for determining whether to grant such an increase.  We agree with the judge’s unfair labor practice findings, but not his entire rationale. 

Initially, we agree with the Respondent that the judge mischaracterized the wage increase withheld in 2002 as a merit-based increase.  In fact, the record shows that it was a structural scale increase.[5]  The judge’s error, however, does not warrant a different result.    

It is well settled that an employer violates Section 8(a)(5) and (1) if it unilaterally changes a term or condition of employment.  NLRB v. Katz, 369 U.S. 736 (1962).  “This is so even if the Union has only won an election, but has not yet been certified as the bargaining representative of the company’s employees.”  NLRB v. Talsol Corp., 155 F.3d 785, 794 (6th Cir. 1998).  A wage increase program constitutes a term or condition of employment when it is an “established practice . . . regularly expected by the employees.”  Daily News of Los Angeles, 315 NLRB 1236, 1239 (1994), enfd. 73 F.3d 406 (D.C. Cir. 1996), cert. denied 519 U.S. 1090 (1997).  Factors relevant to this determination include “the number of years the program has been in place, the regularity with which raises are granted, and whether the employer used fixed criteria to determine whether an employee will receive a raise, and the amount thereof.”  Rural/Metro Medical Services, 327 NLRB 49, 51 (1998).  “[I]t is the unilateral change in the terms and conditions of employment that results in the finding of an 8(a)(5) violation, not the type of wage increase that is continued or discontinued.” Daily News of Los Angeles, supra, 315 NLRB at 1239.   

Here, the record shows that the structural wage increase was a term and condition of employment.  Thus, the Respondent had granted a structural wage increase to employees for at least 4 years prior to 2002.  In addition, the timing of the increase was fixed, as the increases were consistently granted during the first quarter of each year.  Further, the sole criterion for determining the amount of the structural wage increase was fixed (the local wage survey).  Finally, the majority of the Respondent’s employees—at least 80 percent—received this annual first-quarter wage increase, and those increases fell within a narrow range.[6]  Taking all of these factors into account, we find that the annual structural wage increase was an established term and condition of employment by 2002.

That being the case, the Respondent was obliged to maintain the fixed elements of the structural wage increase program—the local wage survey and its timing—and to negotiate with the Union over the discretionary element of the structural wage increase—the amount.  Daily News of Los Angeles, supra, 315 NLRB at 1239.  The Respondent, however, failed on both counts.

First, the Respondent unilaterally changed its established method for determining whether its employees were entitled to a structural wage increase.  As described, prior to 2002 the Respondent conducted a telephone survey of local companies to assess area wages.  In 2002, the Respondent switched to a statewide market survey.  In addition, the Respondent changed the timing of the wage survey from February/March to October.  Further, for the first time, the Respondent considered not only the wage survey, but also its recruitment and retention needs.  By unilaterally making these changes, the Respondent violated Section 8(a)(5) and (1) of the Act.  See Hyatt Regency Memphis, 296 NLRB 259 fn. 2, 285–286 (1989), enfd. 939 F.2d 361 (6th Cir. 1991) (unilateral changes to wage adjustment plan); see also J. P. Stevens & Co. v. NLRB, 623 F.2d 322 (4th Cir. 1980), enfg. in part 239 NLRB 738 (1978) (unilateral alteration to method of computing holiday pay).

Second, the Respondent failed to give the Union notice and an opportunity to bargain regarding the amount of the increase, i.e., its determination that no structural wage increases would be given to employees in 2002.  By such unilateral conduct, the Respondent additionally violated Section 8(a)(5) and (1).  Daily News of Los Angeles, supra.[7]      

iii. the suspension and discharge of employee marquez

Unit employee Ramon Marquez began working for the Respondent in 1994.  Marquez engaged in union activity during the organizing campaign in 2001. The Respondent suspended and then discharged him in July 2002 after he damaged a piece of manufacturing equipment.  The complaint alleges that it was Marquez’ union activity, not the equipment damage, that motivated his suspension and discharge, and that the Respondent thereby violated Section 8(a)(3) and (1) of the Act. 

The judge, however, dismissed those complaint allegations.  The judge found that the General Counsel did not meet his initial Wright Line[8] burden of showing that Marquez’ union activity was a motivating factor in the Respondent’s decision to suspend and discharge him.  Specifically, the judge found that the management official primarily responsible for the adverse actions again Marquez had no knowledge of his union activities.  The judge further found that, even assuming the General Counsel had satisfied his initial burden, the Respondent established that it would have suspended and discharged Marquez in any event based on the equipment damage.  We agree with the judge’s dismissal of these allegations, but we rely only on the General Counsel’s failure to establish that the Respondent had knowledge of Marquez’ union activities.

The Respondent’s suspension and discharge of Marquez was handled by Human Resources Manager Elizabeth Laytong, who had only recently joined the Respondent, in April 2002.  Laytong suspended Marquez, investigated his alleged damage to equipment, and recommended his discharge to Vice President Jim Needles, who approved it without further inquiry. 

The judge specifically credited Laytong’s testimony that she had no knowledge of Marquez’ prior union activity in 2001.  Although there is testimony that Needles had knowledge of certain employees’ union activity, he denied having knowledge of Marquez’ union activity, and there is no evidence to the contrary.[9] 

In these circumstances, we find that the General Counsel failed to establish that the Respondent knew about Marquez’ union activity when it suspended and discharged him.  In particular, Human Resources Manager Laytong’s credited testimony establishes that she had no such knowledge, and it was Laytong who suspended Marquez and effectively recommended his discharge.  In addition, the General Counsel has not shown that Vice President Needles, who made the final discharge decision, was aware of Marquez’ prounion sentiments.  Further, we agree with the judge that the record as a whole does not provide a basis for inferring knowledge.  Absent evidence of knowledge, the General Counsel failed to satisfy his initial Wright Line burden of demonstrating that the suspension and discharge were discriminatorily motivated.  See, e.g., Tomatek, Inc., 333 NLRB 1350, 1353 (2001) (“[C]redible proof of ‘knowledge’ is a necessary part of the General Counsel’s threshold burden, and without it, the complaint cannot survive.”).   

ORDER

The National Labor Relations Board adopts the recommended Order of the administrative law judge, as modified and set forth below, and orders that the Respondent, Gruma Corporation d/b/a Mission Foods, Tempe, Arizona, its officers, agents, successors, and assigns, shall

1. Cease and desist from

(a) Refusing to bargain collectively with United Food and Commercial Workers International Union, Local 99, CLC, by changing employees’ terms and conditions of employment, including discontinuing the employee-of-the-quarter award, withholding the annual structural wage increase, changing the method for determining whether to grant a structural wage increase, and failing to bargain over the amount of the structural wage increase, without first giving the Union notice and an opportunity to bargain. 

(b) Refusing to bargain collectively with the Union by eliminating a bargaining unit position from the sanitation department, by transferring employee Michaela Burgara from the sanitation department to another department, or by subcontracting the sanitation department work, without first giving the Union notice and an opportunity to bargain.

(c) Failing and refusing to provide relevant information requested by the Union for the purpose of carrying out its representational duties. 

(d) Maintaining in employee handbooks, or anywhere else, rules that: (i) prohibit employees from remaining in nonwork areas when they are off duty; (ii) prohibit employees from leaving the premises, their assigned work areas, or ceasing work, without authorization; (iii) prohibit employees from distributing literature of any kind on company property or on customer premises during nonworking times and in nonworking areas; or (iv) prohibit employees from making false statements concerning the Company, its employees, and its products and services. 

(e) In any like or related manner interfering with, restraining, or coercing employees in the exercise of the rights guaranteed them by Section 7 of the Act. 

2. Take the following affirmative action necessary to effectuate the policies of the Act. 

(a) Before implementing any changes in wages, hours, or other terms and conditions of employment of unit employees, notify and, on request, bargain with the Union as the exclusive collective-bargaining representative of the employees in the following appropriate unit:

 

All full-time and regular part-time TQ techs, sanitation techs, receivers, customer service reps, mechanics, production operators, production packers, production sweepers, production ingredients, production maseca dumpers employed by the Respondent at its facilities located at 5860 South Ash Avenue, Tempe, Arizona, and all full-time and regular part-time warehousemen employed by the Respondent at its facilities located at 840 West Carver Road, Tempe, Arizona; but excluding all other employees, office clericals, guards, and supervisors as defined in the Act. 

 

(b) Make the unit employees whole for any loss of earnings and other benefits they may have suffered by reason of the Respondent’s failure to grant structural wage increases in 2002.  Backpay shall be computed in accordance with Ogle Protection Service, 183 NLRB 682 (1970), enfd. 444 F.2d 502 (6th Cir. 1971), with interest as prescribed in New Horizons for the Retarded, 283 NLRB 1173 (1987).

(c) Rescind the unlawful rules contained in the employee handbook that: (i) prohibit employees from remaining in nonwork areas when they are off duty; (ii) prohibit employees from leaving the premises, their assigned work areas, or ceasing work, without authorization; (iii) prohibit employees from distributing literature of any kind on company property or on customer premises during nonworking times and in nonworking areas; and (iv) prohibit employees from making false statements concerning the Company, its employees, or its products and services.

(d) Furnish all current employees with inserts for the current employee handbook that (1) advise that the unlawful rules have been rescinded, or (2) provide the language of lawful rules; or publish and distribute revised handbooks that (1) do not contain the unlawful rules, or (2) provide the language of lawful rules.  Jupiter Medical Center Pavilion, 346 NLRB No. 61, slip op. at 4 (2006).

(e) Discontinue subcontracting bargaining unit work in the sanitation department and notify and, on request, bargain with the Union over any decision to subcontract out bargaining unit work.

(f) Restore the janitorial functions in the sanitation department as they existed prior to September 2003.

(g) Within 14 days from the date of this Order, rescind the unilateral transfer of employee Michaela Burgara from the sanitation department and offer her full reinstatement to her former position as it existed before the unlawful action, without prejudice to her seniority or any other rights or privileges previously enjoyed.

(h) Make Michaela Burgara whole for any loss of earnings and other benefits she may have suffered as a result of the unlawful changes in terms and conditions of employment resulting from eliminating her unit position in the sanitation department. Backpay is to be computed in accordance with Ogle Protection Service, supra, with interest as computed in New Horizons for the Retarded, supra.

(i) Rescind the unilateral change made by terminating the employee-of-the-quarter award, restore the award, and make unit employees whole for any loss of earnings and other benefits they suffered as a result of this unilateral change.  Backpay is to be computed in accordance with Ogle Protection Service, supra, with interest as computed in New Horizons for the Retarded, supra.

(j) Furnish the Union the information it requested in its August 7, 2002 letter.

(k) Preserve and, within 14 days of a request, or such additional time as the Regional Director may allow for good cause shown, provide at a reasonable place designated by the Board or its agents, all payroll records, social security payment records, timecards, personnel records and reports, and all other records, including an electronic copy of such records if stored in electronic form, necessary to analyze the amount of backpay due under the terms of this Order.

(l) Within 14 days after service by the Region, post at its facility in Tempe, Arizona, copies of the attached notice marked “Appendix.”[10]  Copies of the notice written in both English and Spanish, on forms provided by the Regional Director for Region 28, after being signed by the Respondent’s authorized representative, shall be posted by the Respondent and maintained for 60 consecutive days in conspicuous places, including all places where notices to employees are customarily posted. Reasonable steps shall be taken by the Respondent to ensure that the notices are not altered, defaced, or covered by any other material. In the event that, during the pendency of these proceedings, the Respondent has gone out of business, the Respondent shall duplicate and mail, at its own expense, a copy of the notice in both English and Spanish to all current employees and former employees employed by the Respondent at any time since September 2001.

(m) Within 21 days after service by the Region, file with the Regional Director a sworn certification of a responsible official on a form provided by the Region attesting to the steps that the Respondent has taken to comply.

It is further ordered that the complaint is dismissed insofar as it alleges violations not specifically found.

Dated, Washington, D.C.  July 27, 2007

 

 

Robert J. Battista,

Chairman

 

 

 

 

Peter C. Schaumber,

Member

 

 

 

 

Dennis P. Walsh,

Member

 

 

 

 

     (Seal)          National Labor Relations Board

 

APPENDIX

Notice To Employees

Posted by Order of the

National Labor Relations Board

An Agency of the United States Government

 

The National Labor Relations Board has found that we violated Federal labor law and has ordered us to post and obey this notice.

 

federal law gives you the right to

 

Form, join, or assist a union

Choose representatives to bargain with us on your behalf

Act together with other employees for your benefit and protection

Choose not to engage in any of these protected activities.

 

We will not refuse to bargain collectively with United Food and Commercial Workers International Union, Local 99, CLC, by changing employees’ terms and conditions of employment, including discontinuing the employee-of-the-quarter award, withholding the annual structural wage increase, changing the method for determining whether to grant a structural wage increase, and failing to bargain over the amount of the structural wage increase, without first giving the Union notice and an opportunity to bargain. 

We will not refuse to bargain collectively with the Union by eliminating a bargaining unit position from the sanitation department, by transferring employee Michaela Burgara from the sanitation department to another department, or by subcontracting the sanitation department work, without first giving the Union notice and an opportunity to bargain.

We will not fail and refuse to provide relevant information requested by the Union for the purpose of carrying out its representational duties. 

We will not maintain in employee handbooks, or anywhere else, rules that: (i) prohibit you from remaining in nonwork areas when you are off duty; (ii) prohibit you from leaving our premises, your assigned work areas, or ceasing work, without authorization; (iii) prohibit you from distributing literature of any kind on company property or on customer premises during nonworking times and in nonworking areas; or (iv) prohibit you from making false statements concerning the Company, its employees, and its products and services. 

We will not in any like or related manner interfere with, restrain, or coerce employees in the exercise of the rights guaranteed them by Section 7 of the Act. 

We will, before making any changes in wages, hours, or other terms and conditions of employment, notify and, on request, bargain with the Union as the exclusive collective-bargaining representative of the employees in the following appropriate unit:

 

All full-time and regular part-time TQ techs, sanitation techs, receivers, customer service reps, mechanics, production operators, production packers, production sweepers, production ingredients, production maseca dumpers employed by us at our facilities located at 5860 South Ash Avenue, Tempe, Arizona, and all full-time and regular part-time warehousemen employed by us at our facilities located at 840 West Carver Road, Tempe, Arizona; but excluding all other employees, office clericals, guards, and supervisors as defined in the Act. 

 

We will make you whole for any loss of earnings and other benefits, including interest, you may have suffered by reason of our failure to grant structural wage increases in 2002.

We will rescind the unlawful rules contained in the employee handbook that: (i) prohibit you from remaining in nonwork areas when you are off duty; (ii) prohibit you from leaving the premises, your assigned work areas, or ceasing work, without authorization; (iii) prohibit you from distributing literature of any kind on company property or on customer premises during nonworking times and in nonworking areas; and (iv) prohibit you from making false statements concerning the Company, its employees, or its products and services.

We will furnish you with inserts for the current employee handbook that (1) advise that the unlawful rules have been rescinded, or (2) provide the language of lawful rules; or publish and distribute revised handbooks that (1) do not contain the unlawful rules, or (2) provide the language of lawful rules.

We will discontinue subcontracting bargaining unit work in the sanitation department and notify and, on request, bargain with the Union over any decision to subcontract out bargaining unit work.

We will restore the janitorial functions in the sanitation department as they existed prior to September 2003.

We will, within 14 days from the date of the Board’s Order, rescind the unilateral transfer of employee Michaela Burgara from the sanitation department and offer her full reinstatement to her former position as it existed before the unlawful action, without prejudice to her seniority or any other rights or privileges previously enjoyed.

We will make Michaela Burgara whole, with interest, for any loss of earnings and other benefits she may have suffered as a result of the unlawful changes in terms and conditions of employment resulting from eliminating the unit position in the sanitation department.

We will rescind the unilateral change made by terminating the employee-of-the-quarter award, we will restore the award, and we will make you whole, with interest, for any loss of earnings and other benefits you suffered as a result of this unilateral change.

We will furnish the Union the information it requested in its August 7, 2002 letter.

 

Gruma Corporation d/b/a Mission Food

 

John Giannopoulos, Esq., for the General Counsel.

Gerard Morales, Esq., Jacqueline Mendez Soto, Esq., and Lisa Coulter, Esq., for the Respondent.

Martin Hernandez, for the Charging Party <