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.

Champion Enterprises, Inc., d/b/a Champion Home Builders Co. and Carpenters Union Local No. 1109, affiliated with United Brotherhood of Carpenters and Joiners of America.  Cases 32–CA–19152–1, 32–CA–19155–1, 32–CA–19181–1, 32–CA–19279–1, 32–CA–9344-1, 32–CA–19366-1, 32–CA–19424–1, 32–CA–19587–3, 32–CA–19587–4, 32–CA–19619–1, and 32–CA–19766–1

August 16, 2007

DECISION AND ORDER

By Chairman Battista and Members Schaumber
and Walsh

On January 17, 2003, Administrative Law Judge Mary Miller Cracraft issued the attached decision.[1]  The Respondent filed exceptions and a supporting brief, and the Charging Party Union filed limited exceptions and a supporting 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 and briefs and affirms the judge rulings, findings,[2] and conclusions only to the extent consistent with this Decision and Order.[3]

i.  introduction

The Respondent builds prefabricated homes at a plant in Lindsay, California.  After an election, the Board certified Carpenters Local No. 1109 (the Union) as the collective-bargaining representative of the Respondent’s production and maintenance employees on April 10, 2001.[4]  The parties began negotiations on July 23 and held 16 bargaining sessions, but were unable to reach an agreement.  On April 18, 2002, the Respondent withdrew recognition from the Union based on an employee petition it had received the day before, signed by a majority of unit employees, stating that the bargaining unit employees no longer desired union representation. 

The judge found that the Respondent committed several violations of Section 8(a)(1) and (5), including unlawfully withdrawing recognition from the Union.[5]  For the reasons stated in the judge’s decision, we adopt her findings that the Respondent violated Section 8(a)(1) by confiscating union materials from one employee’s work station, and by telling an employee that the Union’s picketing of its dealer would force the Respondent out of business.[6]  For the reasons stated in the judge’s decision, we also adopt her finding that the Respondent violated Section 8(a)(5) by failing to provide the Union with information requested on February 11, 2002.[7]  And, for the reasons set forth below, we adopt the judge’s finding that the Respondent violated Section 8(a)(5) by laying off a majority of the unit employees for 1 day without notifying and bargaining with the Union.[8] 

However, for the reasons stated below, we reverse the judge’s findings that the Respondent solicited employees to report to management the names of prounion employees “who bother them, [or] make crude or insulting remarks,” and violated Section 8(a)(1) by soliciting employees to report prounion employees who “interfere with their ability to work.”  In addition, for the reasons stated below, we reverse the judge’s finding that the Respondent violated Section 8(a)(5) by withdrawing recognition from the Union.[9] 

ii.  unfair labor practices

A.  Alleged Solicitation of Employees to Report Pro-Union Employees’ Conduct

On October 12, the Respondent’s plant manager, Jim Stewart, gave a speech to employees that included the following statements:

 

In recent weeks, I have had complaints from employees about co-workers bothering them to try and get them to join or support the union. I have heard that some employees are being told that if they don’t join the union, they will be fired.  I have also heard reports of employees making crude and very insulting statements about co-workers with whose views they disagree. I want to talk about this.

Each of you has the right to decide for yourself if you want to join the union.  Our Company respects that right.  Employees also have the right to try to convince each other that they should or should not support the union.  We respect that right too. 

But, employees do not have the right to interfere with the work of their co-workers, whether they are talking about the union or about baseball.  And they certainly do not have the right to threaten someone because of his or her position on the Union.  

I cannot prohibit your co-workers from talking to you about the union issue.  Frankly, each of you has the right to express your opinions on the union to each other.  People have the right to argue for their position.  An employee has the right to say to his co-worker or employee: “you will someday wish you had supported the union.”  Because that is just a matter of opinion.  However, no one has the right to threaten a co-worker with harm if he or she does not support the union.

So, if someone is interfering with your ability to do your work, let your foreman know.  We will put a stop to it.

If someone is threatening you with harm or saying that you are going to lose your job if you don’t join the Union, let your foreman know.  We will put a stop to it. [Emphasis in original.]

 

The judge interpreted Stewart’s speech as soliciting employees to report on union supporters’ activities whenever they subjectively believed that they were being “bothered,” “insulted,” or “interfered with.”  While she concluded that the speech was open to varying interpretations, she held that the Respondent, as the author, had to bear the burden of any ambiguities in its content.  Noting that the Board has determined that asking employees to report “threatening” behavior is not unlawful, the judge nonetheless found, and our dissenting colleague agrees, that the speech as a whole solicited reporting on “lawful as well as unlawful activities” and thereby violated Section 8(a)(1).  We find to the contrary. 

In our view, both the judge and the dissent read out of context Stewart’s statements about employees “bothering” their coworkers and making “crude and very insulting statements.”  Stewart plainly did not instruct employees to report when they felt subjectively bothered or insulted by union supporters’ activities.  Instead, he simply repeated complaints employees made to him regarding the conduct of union supporters.  The only things Stewart asked employees to report were “if someone is interfering with your ability to do your work” or “if someone is threatening you with harm or saying that you are going to lose your job if you don’t join the Union.”  Neither of these requests violated the Act.

It is well established that in the interest of maintaining production and workplace discipline, employers can prohibit activity that interferes with work or which causes neglect of job performance.[10]  We find that Stewart’s use of the phrase “interfering with your ability to do your work” encompassed only unprotected activity and was sufficiently specific that the employees would reasonably understand its meaning, particularly when read in context with the balance of the speech.[11]  Thus, the Respondent did not violate the Act by advising employees to report conduct that interfered with their work.  Similarly, Stewart asked employees to report threats.  It is well settled that an employer may lawfully assure employees that it will not allow them to be threatened, and it may ask them to report such conduct because threats directed at employees are properly within the Respondent’s legitimate concerns.[12]  Stewart’s speech thus asked only that employees report unprotected conduct to management. Such requests do not reasonably tend to chill employees in the exercise of their Section 7 rights.  On the contrary, they assist in assuring employees the free exercise of those rights.

Tawas Industries, 336 NLRB 318 (2001), and CMI-Dearborn, Inc., 327 NLRB 771 (1999), relied on by the judge in support of her finding that the speech was unlawful, are not to the contrary.  Tawas involved an employer’s statement that if “employees feel [that] they are being subjected to threats and coercion” because of the “express[ion of] their views” on union affiliation, the respondent would “take the appropriate action.”  336 NLRB at 322.  CMI-Dearborn involved an employer request to report any “threats, coercion or scare tactics used by the union pushers.”  327 NLRB at 775.  In each case, the focus was on the use of the word “coercion” (and in CMI-Dearborn on scare tactics also) as the basis for the violation. The Respondent used no such words here.[13]

Moreover, in this case, unlike in Tawas, the Respondent explicitly affirmed that it would respect the right of employees to solicit (and even argue) for the Union.  Indeed, Stewart’s speech indicated that employees “have the right to try to convince each other that they should or should not support the union” and that employees “ha[ve] the right to express [their] opinions on the union to each other” and “the right to argue for their position.”  In contrast, the employer in Tawas merely stated that the Act protected the employees’ right to express their views on the Union.

In sum, we find that Stewart’s speech taken as a whole did not solicit reports of employees’ protected Section 7 activities, but only sought information regarding instances in which union solicitors interfered with plant production or made unprotected threats of harm and job loss.  Accordingly, we do not find that Stewart’s speech violated Section 8(a)(1) and we dismiss this complaint allegation.

B.  Employee Layoffs

On October 18, Stewart announced to employees that most of the bargaining unit would not work the following day.[14]  That layoff lasted 1 day.  Stewart did not provide the Union with notice or with an opportunity to bargain about the temporary layoff or the selection of employees for the 1-day layoff. 

We agree with the judge that the Respondent had an obligation to notify and bargain with the Union prior to the layoff, and that the Respondent violated Section 8(a)(5) by failing to provide the Union with an opportunity to bargain about the layoff before it was implemented.[15]  The layoff of unit employees is a change in terms and conditions of employment over which an employer generally must bargain. See Tri-Tech Services, 340 NLRB 894 (2003) (and cases cited therein).

The Respondent argues that the October 18 layoff was not a unilateral change over which it was required to bargain because the layoff was consistent with its past practice of employee layoffs.  However, the sole evidence of past practice adduced by the Respondent relates to two plant shutdowns in 2001.  We find that these two instances of layoffs associated with plant shutdowns are insufficient to establish a generalized past practice of layoffs in response to slowdowns in work, particularly when Stewart admitted that the Respondent faced a shortage of work orders nearly every day.  In sum, the paucity of evidence submitted in this case is insufficient to demonstrate a discernable and consistent past practice regarding the implementation of temporary layoffs.  Thus, we conclude that the Respondent unlawfully failed to bargain over the layoff as required by the Act.[16] 

C.  Withdrawal of Recognition

On April 17, 2002,[17] the Respondent received a petition, signed by 89 of the 167 bargaining unit employees, stating that they no longer desired union representation.  The Respondent withdrew recognition the following day.  Consistent with Board precedent that no party challenges in this proceeding, the judge concluded that the Respondent’s withdrawal was based on evidence that the Union actually lost majority support.[18]  However, an employer may not lawfully withdraw recognition from a union where it has committed unfair labor practices that are likely to affect the union’s status, cause employee disaffection, or improperly affect the bargaining relationship. Lee Lumber & Building Material Corp., 322 NLRB 175, 177 (1996) (Lee Lumber II), enfd. in relevant part and remanded in part 117 F.3d 1454 (D.C. Cir. 1997).  Not every employer unfair labor practice will taint evidence of a union’s subsequent loss of majority support. In cases such as this one, where the unfair labor practices do not involve a general refusal to recognize and bargain with the union, “there must be specific proof of a causal relationship between the unfair labor practice[s] and the ensuing events indicating a loss of support.” Id.  In determining whether a causal relationship exists between unremedied unfair labor practices and the loss of union support, the Board considers the following factors: (1) the length of time between the unfair labor practices and the withdrawal of recognition; (2) the nature of the violations, including the possibility of a detrimental or lasting effect on employees; (3) the tendency of the violation to cause employee disaffection; and (4) the effect of the unlawful conduct on employees’ morale, organizational activities, and membership in the union.  Master Slack Corp., 271 NLRB 78, 84 (1984). Considering these factors, we find that the unlawful conduct here was insufficient to taint the petition.

First, all but one of the violations occurred long before the employee petition was signed and Respondent withdrew recognition in April 2002.  Thus, the Respondent’s confiscation of union materials from an employee’s workstation occurred in October, the Respondent’s failure to bargain involved a 1-day layoff in October, and Plant Superintendent Scott’s threat to employee Sahagun that the Union’s picketing of the Respondent’s dealer would force the Respondent out of business occurred in November.  All of these violations occurred between 5 to 6 months before the petition and withdrawal of recognition.  Thus, we find that these incidents were too remote in time to have caused the employees’ disaffection with the Union.  See, e.g., Quazite Corp., 323 NLRB 511, 512 (1997) (withdrawal of recognition was lawful because the findings of unfair labor practices, which occurred 6 months before the employees’ disaffection from the Union, were too remote in time to have caused the employees’ disaffection from the union).[19]  Although the Respondent’s refusal to provide information in response to the Union’s February 11, 2002 request occurred closer in time to the employee disaffection, there was no evidence that the unit employees knew of this violation at the time they signed the petition.  Accordingly, this factor does not support finding a causal relationship between the unfair labor practices and employee disaffection.

Second, we do not find that the nature of the violations supports a finding of taint. The Respondent’s confiscation of union materials from an employee workstation and Plant Superintendent Scott’s threat to employee Sahagun were isolated events involving one employee each.  The General Counsel presented no evidence of dissemination to any other employees.  As to the Respondent’s refusal to provide information requested on February 11, as discussed above, there is no evidence that employees learned of this refusal before expressing their disaffection.

Third, there is no showing that the unlawful conduct had a tendency to cause employee disaffection toward the Union.  At the time of the withdrawal of recognition, the Respondent had met and bargained with the Union on 16 occasions.  There is no allegation or evidence that the Respondent engaged in bad-faith bargaining in those negotiations.  Further, the violations occurred long before the employee petition and—except for the layoff—were isolated and/or unknown by most employees.  As to the layoff, because it lasted only 1 day, and occurred 6 months before the petition, we do not find that it would have a lasting and negative impact on employees’ support for the Union. 

The dissent states that the Respondent’s unfair labor practices were of a serious nature.  Acknowledging that two of the violations were isolated, it focuses on the 1-day layoff and attendant actions, and Stewart’s speech in October.  However, as we have discussed above, we do not find that Stewart’s speech violated Section 8(a)(1).  Further, while the dissent is correct in noting that the 1-day layoff affected the entire bargaining unit, it was an isolated and brief event that occurred 6 months before the petition. Thus, we do not find that it would have a lasting detrimental effect on employees and diminish support for the Union.

Finally, there is no evidence that the foregoing unlawful conduct, occurring 5–6 months before the petition was signed, had an effect on employee morale, organizational activity or membership in the Union.  Consequently, we reverse the judge and find that the Respondent lawfully withdrew recognition from the Union on April 18.[20]

D.  Refusals to Provide Requested Information

The Union, by letter of February 14, requested copies of all personnel documents relating to absenteeism over the past 3 years.  By letter dated March 6, the Respondent agreed to provide this information.  The Respondent also informed the Union in the letter that “[b]ecause of the clerical time it will take to gather this information, we anticipate that we will not have it before April 20th 2002.”[21]  The Union did not object to this proposed timeframe.  The Respondent did not provide the information before it withdrew recognition on April 18. 

Following a lawful withdrawal of recognition, an employer no longer has a duty to provide a union with requested information.[22]  The Respondent’s lawful withdrawal of recognition from the Union occurred 2 days before the earliest date on which the Respondent stated that it would have the requested information and obviated the Respondent’s duty to furnish it.  Accordingly, we reverse the judge’s finding that the Respondent violated Section 8(a)(5) by failing to provide the information.

The Union made separate written requests, on April 22 and May 15, seeking information relevant to collective bargaining.  The Respondent denied these requests based on its withdrawal of recognition.  Because we find that the Respondent lawfully withdrew recognition before the Union made these information requests, there was no duty to furnish any of this information.  Accordingly, we reverse the judge’s finding that the Respondent violated Section 8(a)(5) by failing to respond to these information requests.[23]

E.  Wage Increase

On April 19, the Respondent announced a wage increase for all the unit employees.  As found above, the Respondent lawfully withdrew recognition from the Union the previous day.  This withdrawal extinguished the Respondent’s bargaining obligation. Accordingly, we reverse the judge’s finding that the wage increase constituted a unilateral change violating Section 8(a)(5).[24]

ORDER

The National Labor Relations Board orders that the Respondent, Champion Enterprises, Inc., d/b/a Champion Home Builders Co., Lindsay, California, its officers, agents, successors, and assigns, shall

1.  Cease and desist from

(a) Confiscating union materials from an employee workstation.

(b) Stating to an employee that by picketing the Respondent’s distributor, employees were going to force the Respondent out of business.

(c) Announcing to all employees that it would shut down because of lack of work, laying off a majority of unit employees, selectively recruiting other unit employees to perform unit work, and utilizing nonunit personnel including foremen to perform unit work during the layoff, without first notifying the Union and without affording the Union an opportunity to bargain.

(d) Refusing to provide information to the Union pursuant to its request of February 11, 2002.

(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) Furnish the Union with the information it requested on February 11, 2002.

(b) Make whole all the employees who were laid off on October 19, 2001, for any loss of earnings and other benefits they may have suffered as a result of their unlawful 1-day layoff, less any net interim earnings, plus interest.

(c) Within 14 days after service by Region 32, post at its facility in Lindsay, California, copies of the attached notice marked “Appendix.”[25] Copies of the notice, on forms provided by the Regional Director for Region 32, after being signed by the Respondent’s authorized representative, shall be posted by the Respondent immediately upon receipt 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 or closed the facility involved in these proceedings, the Respondent shall duplicate and mail, at its own expense, a copy of the notice to all current employees and former employees employed by the Respondent at any time since October 4, 2001.

(d) 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.

Dated, Washington, D.C.   August 16, 2007

 

______________________________________

Robert J. Battista,                                  Chairman

 

______________________________________

Peter C. Schaumber,                 Member

 

(seal)            National Labor Relations Board

 

Member Walsh, concurring in part and dissenting in part.

Contrary to my colleagues, I would adopt the judge’s unfair labor practice findings in their entirety.  Thus, I join my colleagues in adopting the judge’s findings that the Respondent unlawfully confiscated union surveys from an employee and threatened employees that their protected picketing activity would force the Respondent out of business.  I also agree that the Respondent committed four separate violations of its duty to bargain related to its October 19 layoff of unit employees, though I write separately to emphasize that the Respondent’s past practice defense to those violations is irrelevant.  Unlike my colleagues, however, I would affirm the judge’s additional findings that the Respondent unlawfully (1) solicited employees to report the protected activities of other employees to management, (2) withdrew recognition from the Union on April 18, 2002, and, after that time, (3) refused to comply with the Union’s information requests, and (4) unilaterally imposed a wage increase.  Those findings are based on well-established principles and undisputed facts, and I find no basis to reverse them. 

i.  the solicitation of employees to report the
protected activities of other employees to
management

Contrary to my colleagues, the judge correctly found that the Respondent violated Section 8(a)(1) on October 12 when Plant Manager Jim Stewart solicited employees to report the protected union activities of other employees to management.  On that date Stewart read a written statement to employees, which, by its terms, was a response to “complaints from employees about co-workers bothering them to try and get them to join or support the union” as well as “reports of employees making crude and very insulting statements about co-workers with whose views [about the Union] they disagree.”  The statement additionally encouraged each employee to tell his foreman if someone was “interfering with your ability to do your work” or “threatening you with harm.”1  Established Board precedent fully supports the judge’s finding of a violation.       

It is well settled that the Act allows employees to engage in persistent union solicitation even when it annoys or disturbs the employees who are being solicited.”  Ryder Transportation Services, 341 NLRB 761, 761 (2004), enfd. 401 F.3d 815 (7th Cir. 2005).  In turn, employers violate Section 8(a)(1), “when they invite their employees to report instances of fellow employees’ bothering, pressuring, abusing, or harassing them with union solicitations.”  Greenfield Die & Mfg. Corp., 327 NLRB 237, 238 (1998).  Such invitations “chill even legitimate union solicitations, which do not lose their protection simply because a solicited employee rejects them and feels ‘bothered’ or ‘harassed’ or ‘abused.”’  Id.  Therefore, an employer’s invitation to report the activities of other employees is unlawful if it is “broad enough to cover mere attempts by union proponents to persuade employees,” or “so vague as to invite employees generally to inform on fellow workers who were engaged in union activity.”  Liberty House Nursing Homes, 245 NLRB 1194, 1197 (1979).  Significantly, even where an employer also encourages employees to report others who “threaten” them, the Board has instructed that the employer’s invitation must be viewed “as a whole.”  See Greenfield Die, supra at 238.     

Here, the judge properly found that Stewart’s speech, viewed in its “total context,” contained an unlawful invitation to report protected activity to management.  In particular, the judge appropriately relied on the references Stewart made in his opening remarks about having received complaints that some employees were “bothering” their coworkers “to try and get them to join or support the union” and harassing other employees by “making crude and very insulting statements about coworkers” with whom they disagreed.  Stewart followed those remarks by declaring, “I want to talk about this.”  Accordingly, Stewart’s express reason for speaking with the employees was to address complaints that included those matters.  Given that emphasis, and that Stewart failed to explain what he meant by “bothering” coworkers, or “making crude and very insulting statements about coworkers” in the context of the union organizing campaign, employees listening to the speech could reasonably believe that Stewart’s later repeated instruction, to “let your foreman know,” included the reporting of such protected activities whenever they felt subjectively bothered, insulted, or interfered with.  Accordingly, the judge correctly found that Stewart’s statement invited employees generally to inform on fellow workers’ protected activities, and thereby violated Section 8(a)(1).  See Tawas Industries, 336 NLRB 318, 322 (2001); CMI-Dearborn, Inc., 327 NLRB 771, 775–776 (1999).

Reversing the judge’s finding of an unlawful solicitation, my colleagues claim that the judge “took out of context” Stewart’s statements about employees “bothering” their coworkers and making “crude and very insulting remarks,” asserting that Stewart “did not expressly instruct employees to report when they were bothered or insulted” but was “simply repeating complaints employees made to him.”  In fact, it is my colleagues who have taken those statements out of context; indeed, they have effectively taken them out of Stewart’s speech altogether.  Stewart’s references to reports of employees “bothering” their coworkers and making “crude and very insulting remarks” clearly illustrated for employees the type of conduct he was concerned about.  It would have been entirely reasonable for the employees to then interpret the remainder of Stewart’s remarks with those examples in mind.  By dismissing Stewart’s express references to those examples, my colleagues have deviated from the Board’s usual course of considering the total context in which an employer invites employees to report employee activities to management, along with all relevant surrounding circumstances.  See, e.g., Greenfield Die & Mfg. Corp., 327 NLRB at 238 (“letter taken as a whole” was unlawful, despite being a statement against “threatening and coercing” coworkers). 

My colleagues also err by relying on Stewart’s statements that the employees have the right to solicit and argue on behalf of the union.  The presence of lawful statements does not mitigate the impact of an unlawful solicitation requesting that employees report the protected activities of other employees to management.  See, e.g., Liberty House Nursing Homes, 245 NLRB at 1197 (finding both lawful and unlawful invitations to report coworkers’ activities).  Indeed, in Tawas Industries, the Board found that the employer unlawfully solicited employees to report other employees’ protected activities based on the total context in which the communication was made, and despite the employer’s statements that “employees have the right to support or not support the union,” and “have the right to express” their views on unionization.  336 NLRB at 322. 

For all of these reasons, I would adopt the judge’s finding that the Respondent violated Section 8(a)(1) by soliciting employees to report the protected activities of other employees to management. 

ii.  the unilateral layoff of the majority of unit
employees, and related unlawful actions

On October 18, 2 weeks after confiscating union material from an employee, and less than 1 week after unlawfully soliciting its employees to report the protected activities of their coworkers, Plant Manager Stewart unexpectedly announced to the employees that its Lindsay facility would be shut down on Friday, October 19, and possibly Monday, October 22, and they would all be laid off.  Following that meeting, the Respondent in fact unilaterally laid off a majority of unit employees from work on October 19, but selectively recruited a few employees to work that day, and also employed foremen and supervisors to perform the unit employees’ work.  The Respondent took all of those actions without prior notice to the Union and without affording the Union an opportunity to bargain about those decisions or their effects on unit employees. 

My colleagues affirm the judge’s findings that the Respondent’s failure to provide the Union with notice and the opportunity to bargain over the shut down of the plant, the layoff of unit employees, the selection of unit employees for work during the shutdown, and the performance of bargaining unit work by supervisors each constituted a separate violation of Section 8(a)(5) and (1) of the Act.  I agree with those findings, but only for the reasons given by the judge.  

In upholding the judge’s findings, my colleagues—although not reaching the issue substantively—attach some significance to the Respondent’s affirmative defense asserting that it lawfully could take such actions based on a theory of past practice.  I would not entertain such a defense.  Under Board precedent, the Respondent’s assertion of a past practice concerning the unlawful layoffs and related actions is irrelevant to its duty to bargain with the Union.  The Board has long held, with court approval, that despite a past practice of instituting economic layoffs, an employer cannot continue to unilaterally exercise its discretion to layoff unit employees after the Board has certified a union to represent the unit employees.  See Adair Standish Corp., 292 NLRB 890 fn. 1 (1989), enfd. in relevant part 912 F.2d 854, 864–865 (6th Cir. 1990); Falcon Wheel Division, 338 NLRB 576, 576–577 (2002) (same).  

iii.  the unlawful withdrawal of recognition

On April 18, the Respondent withdrew recognition from the Union based on an employee petition signed by a simple majority of 89 of the 167 unit employees.  The judge, however, found that the petition was tainted based on the Respondent’s unfair labor practices, and that therefore the Respondent’s withdrawal of recognition violated Section 8(a)(5) and (1).  The majority reverses that finding, in part, because it also reverses the judge’s finding that the Respondent unlawfully solicited employees to report the protected activities of other employees to management in its October 12 speech.  Because I would affirm the unlawful solicitation finding, and because the majority fails to give the appropriate weight to the other pre-withdrawal unfair labor practices, or to properly apply the relevant factors under Master Slack Corp., 271 NLRB 78 (1984), I disagree and would find that the employee petition was tainted and, consequently, that the Respondent’s April 18 withdrawal of recognition was unlawful. 

An employer may not withdraw recognition from a union in the wake of unremedied unfair labor practices that have the tendency to cause employee disaffection from the union.  See RTP Co., 334 NLRB 466, 468 (2001), enfd. 315 F.3d 951 (8th Cir. 2003).  The Board examines the following factors to determine if a causal connection exists between the unremedied unfair labor practices and the subsequent expression of employee disaffection from the union: “(1) [t]he length of time between the unfair labor practices and the withdrawal of recognition; (2) the nature of the illegal acts, including the possibility of their detrimental or lasting effect on employees; (3) any possible tendency to cause employee disaffection from the union; and (4) the effect of the unlawful conduct on employee morale, organizational activities, and membership in the union.”  Master Slack Corp., 271 NLRB at 84.  The necessary causal connection is present here, and warrants the finding that the Respondent’s withdrawal of recognition was unlawful.

With regard to timing, the Respondent withdrew recognition on April 18, 2002, 6 months after it began committing unfair labor practices in October 2001.  Given the nature of the unremedied unfair labor practices, that 6-month period of time is insufficient to diminish the lasting effects of the Respondent’s unlawful conduct on the employees, and therefore the unfair labor practices are not too remote in time to defeat a causal connection.  See, e.g., Beverly Health & Rehabilitation Services, 346 NLRB No. 111 (2006) (employee poll showing loss of majority support was tainted by unlawful conduct that occurred 6–8 months beforehand); Penn Tank Lines, 336 NLRB 1066 (2001) (withdrawal of recognition was unlawful because it was based on decertification petition tainted by employer’s unlawful actions that began 5 months earlier); Williams Enterprises, 312 NLRB 937, 939 (1993), enfd. 50 F.3d 1280 (4th Cir. 1995) (4 months between the employer’s unfair labor practices and the decertification petition not too remote in time).

Overall, the Respondent’s unfair labor practices were of a serious nature tending to have a lasting detrimental effect on employees and to diminish support for the Union.  Although two of the Respondent’s Section 8(a)(1) violations were directed at individuals and were not disseminated to other employees—its October 4 unlawful confiscation of union materials from employee Jesse Harman’s workstation, and its mid-November unlawful threat to employee Carlos Sahagun that the Union’s picketing of its dealer would force the Respondent out of business—the remaining violations are very serious because they affected the entire bargaining unit and bluntly illustrated to the employees the Union’s apparent inability to assist them. 

Within the space of a week in October, the Respondent took a quick succession of unlawful actions that affected the entire bargaining unit and delivered the obvious messages that the Respondent had the discretion to freely act on its own, and that the union was inconsequential in its role as their bargaining representative.  First, on October 12, Plant Manager Stewart made a speech at a meeting of all employees that unlawfully solicited them to report their coworkers’ union activities to management, and promised that he would “put a stop” to those activities.  Just days later, and again at a meeting of all unit employees, Stewart suddenly announced to the employees, with less than a day’s notice, that they would all be laid off from work on Friday, October 19, and possibly also on Monday, October 22, and that the plant would shut down.  This strong demonstration to the employees of the Respondent’s unilateral power to act over their terms and conditions of work was quickly followed by its unilateral layoff of a majority of unit employees, its selective recruitment of a few employees to work on October 19, and its unilateral decision to give the work of the unit employees to supervisors and other nonunit personnel.2  All of these actions directly affected all unit employees, and were of a nature to seriously foster employee disaffection from the Union.  The Respondent demonstrated that it could freely act against union supporters, shut down the plant, lay them off, and take away their work, and that the Union was powerless to protect them.  See Penn Tank Lines, 336 NLRB at 1067 (“Where unlawful employer conduct shows employees that their union is irrelevant . . . the possibility of a detrimental or long-lasting effect on employee support for the union is clear.”).

The final two Master Slack factors focus on the effect of the employer’s unlawful conduct on protected employee activities.  Here, the Respondent, by taking all of its unilateral actions relating to its unlawful layoff of unit employees, and by coercively soliciting unit employees to solicit their co-workers’ union activities so that it could “put an end” to them, ‘“minimize[d] the influence of organized bargaining’ and ‘emphasiz[ed] to the employees that there is no necessity for a collective-bargaining agent.”‘  Id. at 1068 (quoting May Dept. Stores Co. v. NLRB, 326 U.S. 376, 385 (1945)).  In sum, the bulk of the Respondent’s unlawful conduct is of a type that reasonably tends to have a negative effect on union support and to undermine the employees’ confidence in their collective-bargaining representative.  I would therefore find that its unfair labor practices tainted the employee petition, and that the Respondent’s April 18 withdrawal of recognition violated Section 8(a)(5) and (1) of the Act.

iv.  the unilateral wage increase and the
refusals to provide information

On April 20, the Respondent implemented an across-the-board wage increase of 61 cents per hour for all unit employees, and did so without first notifying the Union of its intention to increase wages or providing the Union with an opportunity to bargain over the increase.  After that time, the Respondent also refused to comply with the Union’s requests for information dated February 14, April 22, and May 15.  The judge found that each of those actions constituted a violation of Section 8(a)(5) and (1) of the Act.  The only basis for the majority’s reversal of those findings is that the Respondent took these actions after its April 18 withdrawal of recognition.  See slip op., at 13–14.  Therefore, for the reasons stated by the judge, I would find those additional violations by the Respondent.  In sum, I would adopt the judge’s unfair labor practice findings in their entirety, and issue an affirmative bargaining order. 

Dated, Washington, D.C.   August 16, 2007

 

______________________________________

Dennis P. Walsh,                                     Member

 

              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 confiscate Carpenters Union Local No. 1109 materials from an employee workstation; or state to an employee that by picketing our distributor, employees were going to force us out of business.

We will not announce to all employees that we will shut down because of lack of work, or lay off a majority of unit employees, selectively recruit other unit employees to perform unit work, and utilize nonunit personnel including foremen to perform unit work during the layoff, without first notifying the Union and affording the Union an opportunity to bargain.

We will not refuse to provide relevant requested information to the Union.

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 provide the Union with relevant requested information.

We will make whole all the employees who were laid off on October 19, 2001, for any loss of earnings and other benefits they may have suffered as a result of their unlawful 1-day layoff, less any net interim earnings, plus interest.

 

Champion Enterprises, Inc., d/b/a Champion Home Builders Company

 

Valerie Hardy-Mahoney, Esq. and Karen Ann Seidenstein, Esq., for the General Counsel.

Lindberg Porter Jr., Esq. and Jennifer Jech Simonson, Esq. (Allen Matkins Leck Gamble & Mallory LLP), of San Francisco and Irvine, California, for the Respondent.

Allan Crawley, Esq., of Oakland, California, for the Charging Party.

Paul Bradshaw, Senior Field Representative, Organizing Department, for the Charging Party.

DECISION

Mary Miller Cracraft, Administrative Law Judge.  This case was tried in Visalia, California, on August 27–30, 2002.  The General Counsel alleges that Champion Enterprises, Inc., d/b/a Champion Home Builders Co. (Respondent) violated Section 8(a)(1), (3), and (5) of the Act, culminating in withdrawal of recognition on April 18, 2002, from Carpenters Union Local No. 1109, a/w United Brotherhood of Carpenters and Joiners of America (the Union).1

On the entire record, including my observation of the demeanor of the witnesses,2 I make the following

Findings of Fact

i.  jurisdiction

Respondent is a Michigan corporation with an office and place of business in Lindsay, California, where it is enga