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.

BCE Construction, Inc. and International Brotherhood of Carpenters & Joiners of America, Local # 978.  Cases 17–CA–18556, 17–CA–18619–1, and 17–CA–18619–2

August 31, 2007

DECISION AND ORDER

By Chairman Battista and Members Liebman
and Schaumber

On August 11, 1997, Administrative Law Judge Pargen Robertson issued the attached initial decision in this case.  The Respondent filed exceptions to the judge’s decision and a supporting brief, the Charging Party filed an answering brief to the Respondent’s exceptions, and the General Counsel filed exceptions and a memorandum in support of them.

On June 7, 2000, the National Labor Relations Board remanded the case to the judge for further consideration in light of the Board’s decision in FES, 331 NLRB 9 (2000), supplemental decision 333 NLRB 66 (2001), enfd. 301 F.3d 83 (3d Cir. 2002), which sets forth the analytical framework for refusal-to-hire and refusal-to-consider allegations.

On July 9, 2001, the judge issued the attached supplemental decision. The Respondent filed exceptions to the judge’s supplemental decision and the General Counsel filed an answering brief.

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

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

This case centers on whether the Respondent unlawfully failed to consider and/or refused to hire nine applicants, in violation of Section 8(a)(3) and (1) of the Act. The complaint also alleged that the Respondent discharged an employee in violation of Section 8(a)(3) and (1) of the Act.  Finally, the complaint alleged that the Respondent independently violated Section 8(a)(1) in various respects.

We agree with the judge’s findings, for the reasons he sets forth, that the Respondent violated Section 8(a)(1) of the Act by threatening to discharge employees because of their protected concerted activities,[3] by creating an impression of surveillance of employee union activities, by forbidding employees to talk about the Union,[4] and by interrogating employees about their protected and union activities.  However, concerning this last violation, we base our finding on the Respondent’s unlawful conduct in an incident on February 6, 1996,[5] when Superintendent Leonard DeClue asked employee Anthony Twitty if employee Terrence McCulloch was also in the Union.  We find it unnecessary to pass on the other incidents of DeClue’s alleged unlawful interrogation on February 6 and April 4 because they would be cumulative and have no effect on the remedy.  See W & M Properties of Connecticut, Inc., 348 NLRB No. 11 fn. 1 (2006); V&B, Inc., 322 NLRB 996 fn. 2 (1997), enfd. mem. 132 F.3d 1483 (D.C. Cir. 1997).

We also adopt the judge’s finding that the Respondent violated Section 8(a)(1) of the Act by informing employees that it would be futile to support unionization.  We adopt this finding, pro forma, because we agree with the Charging Party’s contention that the Respondent’s exception on this point fails to conform to Section 102.46 of the Board’s Rules and Regulations.  We note that the Respondent excepted to the judge’s finding of this violation in its enumerated exceptions.  The Respondent therein stated only that the judge’s decision was “contrary to the law establishing the charges” and “contrary to the evidence adduced at the hearing.”  Although the Respondent set forth specific arguments on the merits for all other points in its exceptions, it did not do so for this one.  Further, it failed to “designate by precise citation of page the portions of the record relied on” (Sec. 102.46(b)(1)(iii)).  See Holsum de Puerto Rico, 344 NLRB No. 85 fn. 1 (2005), enfd. 456 F.3d 265 (1st Cir. 2006); QSI, Inc., 346 NLRB No. 97, slip op. at 2 (2006).  Indeed, the Respondent did not respond at all to the Charging Party’s procedural attack.

Finally, we agree with the judge, for the reasons he sets forth, that the Respondent violated Section 8(a)(3) and (1) of the Act.  The judge, applying the Board’s holding in FES, above, concluded that the Respondent unlawfully refused to consider for hire, and refused to hire, the following nine individuals: Jim Carsel, Larry Sowers, Davis Carson, Michael Rand, Kenneth Owens,[6] Ted Birch, Steven Wilson, Robert Wirth, and William Grooms.  In its exceptions to the judge’s supplemental decision, the Respondent submits that the judge erred in failing to find that the Respondent’s “hiring policy” would in any event have resulted in its hiring applicants other than the alleged discriminatees.  The judge specifically discredited the Respondent’s evidence.  We adopt the judge’s decision.[7]

Finally, the judge, applying Wright Line,[8] concluded that the Respondent unlawfully discharged employee Anthony Twitty. In its defense, the Respondent’s chief argument is that Twitty was not discharged.  Rather, according to the Respondent, Twitty stopped showing up for work.  However, the judge discredited the Respondent’s defense that Twitty quit.  We adopt the judge’s decision.[9]

Amended Remedy

Having found that the Respondent discriminatorily refused to hire the nine applicants, and refused to consider them for employment, the Respondent must make them whole for its unlawful conduct against them.  The duration of their backpay period shall be determined in accordance with Oil Capitol Sheet Metal, 349 NLRB No. 118 (2007).[10]  Backpay shall be computed in accordance with F. W. Woolworth Co., 90 NLRB 289 (1950), and interest shall be computed in accordance with the New Horizons for the Retarded, 283 NLRB 1173 (1987).[11]

ORDER

The National Labor Relations Board adopts the recommended Order of the administrative law judge as modified and set forth in full below and orders that the Respondent, BCE Construction, Inc., Branson, Missouri, its officers, agents, successors, and assigns, shall take the action set forth in the Order as modified.

1. Cease and desist from

(a) Threatening to discharge its employees because of their protected concerted activities.

(b) Creating the impression that it is engaged in surveillance of its employees’ union activities.

(c) Discriminatorily prohibiting its employees from talking about the Union.

(d) Interrogating its employees about their union activities.

(e) Refusing to consider for hire and refusing to hire employees that show an affiliation with, or an intent to organize for, International Brotherhood of Carpenters & Jointers of America, Local # 978, or any other labor organization.

(f) Discharging its employees because of their protected and union activities.

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

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

(a) Within 14 days from the date of this Order, offer employment to Jim Carsel, Larry Sowers, Davis Carson, Michael Rand, Kenneth Owens, Ted Birch, Steven Wilson, Robert Wirth, and William Grooms, in the positions for which they applied or, if those positions no longer exist, to substantially equivalent positions, without prejudice to their seniority or any other rights or privileges to which they would have been entitled absent the discrimination against them.

(b) Make whole the nine discriminatees identified in paragraph (a) for losses sustained by reason of the discrimination against them as set forth in the amended remedy section of this Decision.

(c) Within 14 days from the date of this Order, offer Anthony Twitty full reinstatement to his former job or, if that job no longer exists, to a substantially equivalent position, without prejudice to his seniority or any other rights or privileges previously enjoyed.

(d) Make Anthony Twitty whole for any loss of earnings or other benefits suffered as a result of his unlawful discharge, in the manner set forth in the remedy section of the judge’s decision.

(e) Within 14 days from the date of this Order, notify, in writing, the nine discriminatees who applied for employment at the Respondent’s office on February 22, 1996, and who were unlawfully denied employment, that any future job applications will be considered in a nondiscriminatory manner.

(f) Within 14 days from the date of this Order, expunge from its records all reference to the unlawful actions taken against the nine discriminatees and Twitty, and within 3 days thereafter advise them in writing that this has been done and that these actions shall not be used against them in any manner in the future.

(g) 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.

(h) Within 14 days after service by the Region, post at its facility in Branson, Missouri, and at each of its various job locations, copies of the attached notice marked “Appendix.”[12]  Copies of the notice, on forms provided by the Regional Director for Region 17, 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 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 January 16, 1996.

(i) Within 21 days after service by the Region, file with the Regional Director, Region 17, 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 31, 2007

 

 

Robert J. Battista,

Chairman

 

 

 

 

Wilma B. Liebman,

Member

 

 

 

 

Peter C. Schaumber,

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 threaten to discharge our employees because of their protected concerted activities.

We will not create the impression that we are engaged in surveillance of our employees’ union activities.

We will not discriminatorily prohibit employees from talking about International Brotherhood of Carpenters & Joiners of America, Local # 978 or any other labor organization.

We will not interrogate our employees about their union activities.

We will not refuse to employ or consider for employment anyone because of our belief that the applicant may engage in organizing activity for International Brotherhood of Carpenters & Joiners of America, Local # 978, or any other labor organization.

We will not discharge our employees because of their protected and union activities.

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, within 14 days from the date of the Board’s Order, offer employment to the nine discriminatees listed below in the positions for which they applied, or if those positions no longer exist, to substantially equivalent positions, without prejudice to their seniority or any other rights or privileges they would have enjoyed.

 

Jim Carsel                      Ted Berch

Larry Sowers                 Steven Wilson

Davis Carson                                Robert Wirth

Michael Rand                               William Grooms

Kenneth Owens

 

We will make those nine discriminatees whole for any loss of earnings and other benefits suffered as a result of our refusal to hire them.

We will, within 14 days from the date of the Board’s Order, notify in writing the nine discriminatees who applied for employment at our office on February 22, 1996, and who were denied employment, that any future job applications will be considered in a nondiscriminatory manner.

We will, within 14 days from the date of the Board’s Order, offer employment to Anthony Twitty to his former job or, if that job no longer exists, to a substantially equivalent position without loss of benefits.

We will make Anthony Twitty whole for any loss of earnings and other benefits suffered as a result of our discharge of him.

We will expunge form our records all reference to the actions taken against the nine discriminatees and Anthony Twitty and advise them in writing that this has been done, and that such acts shall not be used against them in any manner in the future.

 

BCE Construction, Inc

Stanley Wilson, Esq., for the General Counsel.

Thomas M. Moore, Esq., of Kansas City, Missouri, for Respondent.

Michael J. Stapp, Esq., of Kansas City, Kansas, for the Charging Party.

DECISION

Pargen Robertson Administrative Law Judge.  This matter was heard in Springfield, Missouri, on May 5 and 6, 1997. The charge in Case 17–CA–18566 was filed on February 7 and amended on April 30, 1996. The charge in Case 17–CA–18619–1 was filed on May 8, 1996. The charge in Case 17–CA–18619–2 was filed on May 8, 1996. A consolidated complaint issued on July 17, 1996.

Respondent, Charging Party (Union), and General Counsel were represented and were afforded full opportunity to be heard, to examine and cross-examine witnesses, and to introduce evidence. Respondent, Charging Party, and General Counsel filed briefs.

On consideration of the entire record and briefs, I make the following

Findings of Fact

i. jurisdiction

Respondent admitted that at material times it has been a corporation with a place of business in Branson, Missouri, where it has been engaged as a general contractor in the construction business doing commercial construction; that during the 12 months ending May 31, 1996, in conducting those business operations, it purchased and received at its facility and jobsites in Missouri goods and services valued in excess of $50,000 directly from points outside Missouri; and that it has been an employer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the National Labor Relations Act (Act).

iii. labor organization

Respondent admitted that the Charging Party (Union) has been a labor organization within the meaning of Section 2(5) of the Act.

iv. the unfair labor practice allegations

Terrence McCulloch, a carpenter, is a member of the Union. He worked for Respondent from January 16–30, 1996. McCulloch was directed by the Union to apply for work with Respondent. He did not reveal his union affiliation when hired by Respondent.

McCulloch was hired by Superintendent Leonard DeClue after he applied at Respondent’s Cooper Park Tennis Stadium job. Respondent showed that its superintendents were both fully responsible and completely independent to run their respective projects. DeClue was Respondent’s highest official on the Cooper Park job.

A. Section 8(a)(1): By Leonard DeClue:
 Threat of Discharge

At the end of their work shift on January 16, 1996, DeClue talked with McCulloch. McCulloch tape recorded the conversation. During the conversation DeClue told McCulloch that one of three employees on the job was causing him grief, that “somebody is causing me some real grief with my Labor Relations Board.”1  He went on to say, among other things:

 

They don’t think I’m paying them good enough and somebody here on this job has been stealing my documents out of my trailer and I’m just gonna tell you this between me and you and don’t mention it to them guys, but I’m gonna find out who done it and I’m gonna fire their ass.

 

. . . .

 

I don’t know what kind of shit Tony (Anthony Twitty) is putting to you, but he, I think, you know, I think that’s my culprit, I’m not sure about it. I can’t, you know, I can’t say for certain, but I guarantee you not one of em will own up to it, whoever is doing it to me. But I’ve had some real f—kin’ grief on this job. I been paying $13.70 or whatever it is, laborer scale, to those guys and they’re whining, you know, wanting more money. I don’t know what the f—k to do, you know what I’m saying.

 

. . . .

 

And they just ain’t, you know, they haven’t been getting it done for me and some chickenshit has went behind my back and back stabbed me right square in the ass and I’m gonna find out who it is and when I do, he’s gone. So that’s just between me and you, so I don’t know what kind of smoke he’s put to you there, but

 

. . . .

 

I know I’ve got some grief on this job and somebody here has been copying my records and turning them over to the Labor Relations Board. They called a grievance against me . . . about it. These guys got a problem, they just need to come to me and talk to me, you don’t like that. If you come talk to me, I might deal with it, but if you try to stick it in my back like that, I’ll get rid of his ass in a heartbeat, you know. I don’t need that shit. I know it wasn’t you, you just got here.

1. Findings: Credibility

The evidence as to this issue is not in dispute. I find in view of the full record, that the tape recordings of Terrence McCulloch’s conversations with Leonard DeClue are accurate.

2. Conclusions

An examination of the taped conversation shows that Leonard DeClue threatened that he would fire the employee causing him grief. DeClue mentions that the suspect employee is stealing and copying records from his trailer, but the overall conversation shows that it is the suspected activity of revealing evidence to the “Labor Relations Board,” bringing a grievance against DeClue and inciting the employees to demand more money, that are the true motivating factors behind DeClue’s threat. The credited tape recording shows that DeClue suspects that employee “Tony” Twitty is the employee that caused all those problems for DeClue. The suspected activity of giving evidence to the state division of labor standards, filing a grievance and encouraging employees to seek higher wages, are all protected concerted activity under the National Labor Relations Act (Act). DeClue’s threat against an employee because of the employee’s suspected activity constitutes a violation of Section 8(a)(1) of the Act.

B. Create Impression of Surveillance and Told of Futility of Unionization: Promulgated Rule Against
 Talking About the Union

McCulloch tape recorded a conversation with employee George Pallicere on the morning of January 24, 1996. The tape recording continued when Leonard DeClue arrived. McCulloch told DeClue that McCulloch was a member of the Union and that he was on that job to try and organize Respondent. DeClue replied that would not happen because Respondent “ain’t gonna go union.” McCulloch told DeClue that the Union also wanted him to investigate prevailing wage. DeClue told McCulloch that he already knew that McCulloch was union. De Clue said:

 

I know how to make phone calls, too. I make phone calls on everybody anymore. I’ve had such f—kin’ reason. I ain’t puttin up with that shit. They’re paying the minimum wage, they’re paying union scale. This ain’t a carpenter’s job, this is a f—kin’ concrete job. There you go.

 

Terrence McCulloch and DeClue had a second conversation on the morning of January 24, 1996. Among other things DeClue told McCulloch:

 

BCE is not gonna go union and I don’t want to hear any union bullshit on my job while you’re out here working with my guys, cause you’re not entitled to do that. If you are a union organizer, you can do that after work on your time, but not on my time while you’re out here working.

 

DeClue agreed that McCulloch could talk about the Union before and after work and during lunch. He told McCulloch that he did not want to hear any union talk on the job and that BCE had told him they were not going to go union. McCulloch testified that no one had said anything about restrictions on talking until DeClue told him that he could not discuss the Union while on the job. In fact the employees did talk while working.

DeClue told McCulloch that he had been injured by the Carpenters and the Steelworkers unions when he started a company in 1978, and that those unions had been unable to man his job. DeClue told McCulloch the he would be tickled if McCulloch stayed on the job even if only part-time, until it finished but the scale was what he had been paying.

1. Findings: Credibility

DeClue admitted that he did tell Terrence McCulloch that he could not talk about the Union while he was on the job.

Again, as shown above, I fully credit the tape recordings of conversations involving Leonard DeClue.

2. Conclusions

After McCulloch told Leonard DeClue that he was a union organizer, DeClue replied that he knew he was with the Union in that he had made phone calls. General Counsel alleges that by holding out that he was aware of McCulloch’s union activities, even though DeClue subsequently testified that he was actually unaware of McCulloch’s union affiliation until told by McCulloch, Respondent created the impression of surveillance.  Gupta Permold Corp., 289 NLRB 1234 (1988). Leonard DeClue had full authority to discharge the Cooper Park employees. He was the only contact the employees had with Respondent. As shown above, he had already threatened to discharge an employee for going to the State division of labor standards and he told McCulloch that Respondent would not go union. As shown below other employees learned of his comments to McCulloch. Respondent argues that the actions of McCulloch and Anthony Twitty show that DeClue was not successful in coercing the employees. However, the test is not whether DeClue was successful but whether his comments tend to coerce the employees. I am convinced that the comments were coercive and constitute violation of Section 8(a)(1) of the Act.

The tape recording also shows during a later conversation on January 24 that DeClue prohibited McCulloch from talking to other employees about the Union during worktime. The full record revealed without rebuttal, that the employees were permitted to talk about anything other than the Union during work. Before January 24 there had been no restrictions on employees talking. As shown below the credited evidence also showed that in a later conversation Leonard DeClue admitted to employee Anthony Twitty that he had told McCulloch that McCulloch could not talk union during work. That evidence illustrates the pervasive nature of DeClue prohibition.

Respondent cited Central Hardware Co. v. NLRB, 439 F.2d 1321 (8th Cir. 1971), in arguing that an employer has the right to prohibit union solicitation during work hours. Central Hardware is not applicable here where the issue was not solicitation but talking and the record show that employees were allowed to talk about anything other than the Union.

The prohibition on talking constitutes a discriminatory rule designed to coerce employees into foregoing discussions about the Union. McGraw of Puerto Rico, Inc., 322 NLRB 438 (1993); Willamette Industries, 306 NLRB 1010 (1992); Industrial Wire Products, 317 NLRB 190 (1995); Marriott Services, 318 NLRB 144 (1995).

In view of the full record including especially comments made by Superintendent Leonard DeClue regarding the employees’ union and other protected activities, I find that Respondent engaged in 8(a)(1) violations by creating the impression of surveillance of its employees union activities; by telling employees that efforts to organize Respondent’s jobs will be futile and by promulgating a discriminatory rule against talking about the Union. DeClue made comments about knowing of union activity at a time when employees were making initial efforts to support the Union. Comments such as those by DeClue illustrating surveillance, the futility of organizing efforts and rules against discussing the Union, tend to be especially coercive at that early stage of union activity.

C. Interrogated Employees

1. February 6, 1996

During a February 6, 1996 phone conversation Leonard DeClue asked Anthony Twitty what the employees were doing walking a picket line. Twitty replied that he felt his rights had been violated when DeClue told Terry McCulloch that he didn’t want anybody talking any union shit on his job. DeClue asked Twitty if he was “joining the f—kin’ union now?” In the conversation DeClue denied that he had ever said Twitty could not talk about unions but he admitted telling Terrence McCulloch that he “didn’t want anybody talking any union shit on (his) job.” At the end of their phone conversation DeClue told Twitty to “get your ass up here and talk to me like a man.”

Twitty went to the job where he and DeClue talked. Donny Shuler was also present. Twitty tape recorded that conversation. DeClue asked if Mike McCulloch “was in the union too?” Twitty replied that Mike was not in the union as far as he knew. Twitty and DeClue argued about Terrence McCulloch’s right to talk about the Union while on the job. DeClue accused Twitty of calling him a “f—kin’ liar” by saying that DeClue had said that nobody could talk about the Union on the job. DeClue said that he was talking specifically to Terrence McCulloch and did not include the other employees in that comment. DeClue said that he said to Terrence McCulloch only that he could not talk about the Union on the job. Twitty explained that he was walking the picket line because he thought he heard DeClue tell Terrence McCulloch that none of the employees could discuss the Union on the job.

2. April 4, 1996

On April 3, Twitty and another employee named Greg, incorrectly drilled holes in a landing for handrails. DeClue came to the job the following morning and talked with Twitty. DeClue was angry. He asked Twitty who was going to pay for the mistake. He said, “I know you filed charges with me with the National Labor Relations Board . . . if it wasn’t for the fact that I was afraid you would go file more charges on me, I’d fire your ass a long time ago.”  Twitty denied that he had filed charges against DeClue.

DeClue then asked Twitty “Have you gone working for the union now?”

DeClue and Twitty had another conversation that afternoon. Twitty recorded that conversation. DeClue repeated that Twitty would have been gone a long time but for the possibility that he would file charges against DeClue.

3. Findings: Credibility

I credit the tape recordings and the testimony of Anthony Twitty. As shown herein I do not credit the testimony of Leonard DeClue. I make that finding on the basis of his demeanor and the full record including evidence showing that DeClue’s version of why Twitty was terminated conflicted with Respondent’s statement of position to the NLRB.

4. Conclusions

The credited record shows that Leonard DeClue asked why Twitty was picketing the job. DeClue asked Twitty if he was joining the Union. DeClue asked if Mike McCulloch, another employee, was in the Union. DeClue prohibited Twitty from picketing Respondent’s Cooper Park job.

The credited evidence shows that DeClue again interrogated Twitty on April 4, 1996, as to whether Twitty had gone working for the Union. The evidence shows that Anthony Twitty never did reveal himself to be a union supporter.

I find that DeClue unlawfully interrogated Twitty about employees’ union activities in February and April 1996. At the time of those conversations the union organizing campaign was not covert and it was not shown that Anthony Twitty was ever a known union advocate. The record illustrated that Respondent through Leonard DeClue took a strong position in opposition to the Union. The information sought by DeClue included whether employees Mike and Terrence McCulloch and Anthony Twitty were union members. DeClue was the highest ranking supervisor on the Cooper Park Tennis job with full authority to discipline including discharge. The record shows that Anthony Twitty was not truthful in his response to DeClue. Twitty untruthfully denied that he was affiliated with the Union. There was no showing that Respondent had a valid purpose in seeking to determine the extent of its employees’ union activity. DeClue did not tell Twitty why he needed the information and he did not assure Twitty against reprisals. The above convinces me that DeClue’s questioning was coercive even though one of the standards for determining that question was not litigated. There was no evidence offered regarding the history of Respondent’s attitude towards its employees. Bourne v. NLRB, 332 F.2d 47 (2d Cir. 1964); Cooper Tire & Rubber Co. v. NLRB, 957 F.2d 1245, 1255–1256 (5th Cir. 1992); Baptist Medical System, 288 NLRB 1160 (1988); Southwire Co., 282 NLRB 916 (1982); and Rossmore House, 269 NLRB 1176 (1984); and Sunnyvale Medical Clinic, 277 NLRB 1217 (1985).

Respondent cited NLRB v. McCulloch Environmental Services, 5 F.3d 923 (5th Cir. 1993), in arguing that Respondent had a valid purpose in interrogation of Twitty (i.e., the cause of his picketing). However, DeClue did not limit his questioning to the cause for picketing. DeClue also asked Twitty about employees becoming union members. There was no legitimate purpose shown to support that inquiry. That interrogation tends to coerce employees in the exercise of their rights to engage or refuse to engage in union activities.

D. Section 8(a)(3)

1. February 22, 1996 refusal to hire

Jim Carsel, an organizer for the Carpenters District Council in Kansas City, applied for work along with several other applicants on February 22, 1996. There were nine applications including those of Jim Carsel, Michael Rand, Ted Berch, Robert Wirth, Larry Sowers, Kenneth Owens, Steven Wilson, William Grooms, and Davis Carson. General Counsel submitted a video recording and a transcript of the applicants in Respondent’s office on February 22.

When Carsel greeted Respondent’s receptionists on February 22, he announced that he and the other eight applicants were with the Union and would like to apply for work. Carsel told the receptionists that they were willing to work under Respondent’s terms and conditions of employment and the money.

Several of the February 22 applications included comments to the effect that the applicant was a union organizer that would try to organize Respondent’s job during his own time.

Carsel went to Respondent’s Boatman’s Bank job in December 1995 and talked with Superintendent Rick Shuler. Ken Shuler another union representative and a cousin of Rick Shuler, was with Carsel. Rick Shuler said he was having a hard time getting qualified help. Carsel asked how he felt about having union help. Rick Shuler replied that he wished it was all union and that way he did not have to worry about it. Carsel asked about the process of applying for work. Rick Shuler told him to put in applications down at BCE in Branson, Missouri, and the office would send the applications out to the various job superintendents.

Jim Carsel and Danny Hyde, from the Union, went to Respondent’s Branson City Hall site about a week after February 22, 1996, and talked with Superintendent Robert Younger. Carsel and Hyde had on jackets that identified them as being from the Carpenters Union. Younger told them that he might need some help and that they would have to go to the BCE office and apply for work. He said that the applications would then be sent to the various job superintendents. This was the same information Carsel had received from Respondent’s Boatman’s Bank job Superintendent Rick Shuler.

Rick Shuler testified that his cousin, Ken Shuler, is business agent for the Plumbers Union. He recalled talking with Ken Shuler and Jim Carsel while at the Boatman’s Bank job. Shuler testified that he did not recall talking to Carsel and Ken Shuler about the Union or about hiring employees. He admitted on cross that they could have talked about hiring and that he did not remember it.  According to Shuler, he could hire from applications sent to him from the main office or he could hire people walking in to the job.

Shuler testified that since he started working for Respondent in June 1995 he has hired only one employee that had no previous experience with Respondent. That was James Glover and Shuler has known Glover for 20 years. Shuler contacted Glover about working for Respondent and he hired Glover as a laborer on the Southwest Power job. The parties stipulated that no job application was included in Glover’s personnel file.

Although Shuler testified that he hired Glover as a laborer, Glover’s pay record shows that he was paid for concrete construction, concrete floors, carpentry, and dry wall construction.

At the time he hired Glover, Shuler had two other employees on that job. Those were Shane Perkins and Shane McGinnis. Perkins and McGinnis came to the Southwest Power job from another of Respondent’s jobs, the Cooper Tennis Stadium job. Subsequently Leonard DeClue worked for Shuler on the Southwest Power job. DeClue was a leadman. DeClue brought some of his people from the Cooper Tennis job over to the Southwest Power job.

Rick Shuler testified that Carsel has visited him on the Southwest Power job. Ken Shuler was with Carsel at that time too.

Shuler was shown the employment applications of February 22, 1996. He testified that he received copies of those applications from Respondent’s office. He also recalled receiving a copy of Robert Teitel’s application. Shuler testified that he does not recall any of those applicants including Robert Teitel, actually coming on his jobsite.

Rick Shuler testified that he has never hired anyone whose application was sent out to him by Respondent’s office. He has received no instructions from Respondent about how to handle those applications.

On cross-examination Shuler testified that he along with Leonard DeClue and another superintendent, Larry Wright, sat down together with Respondent’s attorney and discussed their anticipated testimony.

Robert Teitel testified that he is a carpenter and has been a member of the Union for 3 years. He was a member of another Carpenters’ local before becoming a member of the Union. Teitel talked to Respondent Superintendent Bob Younger at the Branson City Hall job about January 15, 1996. Younger told Teitel that he did not need anyone at that time but to check back in a week. Teitel did nothing to reveal his affiliation with a union.

Teitel checked back a week later and Younger told him to check back again in another week. On his third visit to the site, Younger told Teitel that he did not do the hiring at that site. Younger said that Teitel needed to go to the main office in Branson and fill out an application. Teitel went to Respondent’s main office on February 8, 1996, where he talked to a woman. He was given an application which he filled out and returned to the woman. She told Teitel that she would fax his application out to all the job superintendents and that if anyone of them needed a carpenter they would call Teitel at home.

Robert Teitel has heard nothing from Respondent.

The Union subpoenaed personnel files from Respondent and none of those files contained an application for work.

Larry Wright is Respondent’s superintendent on its James River Power Station job. He has handled several jobs for Respondent since 1991, and he has always been in charge of hiring and firing on the particular job. He formerly worked for Davern Schoonover. The employer was Schoonover Brothers, a union company and Wright worked for it in the late 1960’s or early 1970’s.

Wright explained Respondent’s hiring procedure. The superintendent may select new hires from applications sent to them from the main office or they may select people from previous jobs. He may also hire someone that comes on the jobsite looking for work. Wright could recall only one applicant that he has hired after receiving his application from Respondent’s office. In that instance he first checked with a former employer listed on the application, then contacted the applicant. Normally, when Wright receives applications from the office he looks over the application then files it. He testified that he did not hire any of the alleged discriminatees because when he received their applications from the office he did not need any new employees.

After reviewing the applications of the alleged discriminatees while testifying, Larry Wright agreed that all the applicants appeared to be qualified to perform some of Respondent’s work.

Wright testified that he was never prohibited by Respondent from hiring anyone with a union background.

Kendall Schoonover, Respondent vice president, recalled receiving the batch applications of the alleged discriminatees. He does not hire anyone for the field and he does not conduct interviews for those jobs. Schoonover could not recall any field applicant other than applicants for superintendent positions, ever being interviewed in the main office. Respondent currently has four superintendents, Rick Shuler, Larry Wright, Leonard DeClue, and Kenny Green. All field employees other than superintendents, are hired by the respective job superintendent. The job, or project, superintendent has 100 percent control and is 100 percent accountable for the respective job.

Schoonover testified that he does not know why none of the alleged discriminatees were hired.

Leonard DeClue testified that the Cooper Park Tennis job was his first job after being employed by Respondent. DeClue testified that he did not hire any of the alleged discriminatees because none of them came to the job site. He did not hire Robert Teitel because he did not need anyone at the time Teitel applied. Subsequently, on cross-examination, DeClue testified that he did not hire any of the alleged discriminatees because each applicant listed carpenter as the job sought and he did not need carpenters.

2. Findings: Credibility

In consideration of the full record and his demeanor I find that Jim Carsel truthfully testified that Superintendents Shuler and Younger informed him of the procedure for applying for work with Respondent. To the extent there are conflicts, I do not credit the testimony of Rick Shuler or Robert Younger. Shuler admitted that he talked with Carsel and Ken Shuler while working on the Boatman’s Bank job and he admitted that they may have talked about hiring even though he testified that he did not recall them discussing that subject. I credit Rick Shuler’s testimony that he could hire from applications that he received from Respondent’s main office.

I credit the testimony of Robert Teitel in view of his demeanor and the full record. That credited testimony shows that after Teitel was told twice to check back with superintendent Bob Younger, Younger told him around January 29, 1996, that it would be necessary for Teitel to apply at Respondent’s main office.

The credited testimony showed that Respondent advised all potential job applicants that were known to be affiliated with the Union, that the procedure for hiring required them to apply at Respondent’s office. After being told to check back with superintendent Bob Younger on two occasions, Robert Teitel was also advised that he must apply through Respondent’s office.

The record evidence including the testimony of Larry Wright and Kendall Schoonover proved that Respondent rarely hired from applications made at its office. However, the credited evidence showed that none of the potential applicants known to be affiliated with the Union were ever advised to also apply at respective jobsites.

As shown herein I do not credit the testimony of Leonard DeClue. I base that determination of DeClue’s demeanor and the full record.

3. Conclusions

General Counsel alleged that Respondent refused to consider for hire and to hire nine job applicants from February 22, 1996, because each of those nine applicants were shown to be affiliated with the Union.  NLRB v. Town & Country Electric, 516 U.S. 85 (1995); Town & Country Electric, 309 NLRB 1250 (1992); Waco, Inc., 316 NLRB 73 (1995); Fluor Daniel, Inc., 311 NLRB 498 (1993); Casey Electric, 313 NLRB 774 (1994); and AJS Electric, 310 NLRB 121 (1993).

In J. E. Merit Constructors, 302 NLRB 301, 303–304 (1991). The Board applied the following standard in a refusal to hire question: (1) the applications were filed during hiring stages, (2) the Respondent knew of their source, (3) it harbored union animus, and (4) it acted on that animus in failing to hire.

There is no dispute but that Respondent received the applications. Applications for the below named alleged discriminatees were submitted to Respondent’s office on February 22, 1996. Respondent made no effort to look behind the matters stated on the applications. The applicants were shown to be qualified to perform some of Respondent’s work:

 

        Jim Carsel               Michael Rand

        Ted Berch               Robert Wirth

        Larry Sowers          Kenneth Owens

        Steven Wilson         William Grooms

        Davis Carson

 

None of the applicants were hired by Respondent. None were shown to have been considered for hire.

As to the question of whether Respondent was hiring when the applications were submitted on February 22, the Respondent’s records2 show that it hired more than nine employees over the next 2 months. Two were hired on the day after the alleged discriminatees submitted their applications. Those two, Robert Bidwell and Gregory Carr, were hired on February 23, 1996, at the Cooper Park Tennis Stadium job under Superintendent Leonard DeClue. In consideration of Respondent’s records including workmen’s compensation codes, Bidwell was shown to perform concrete construction and Gregory Carr performed concrete construction and carpentry.

On March 11, 1996, Respondent hired two more employees at the Cooper Park Tennis Stadium. Mark Daniel and Lloyd Trail both performed carpentry work on that job.

On March 20, 1996, Respondent hired James Glover. Glover worked at the Southwest Power Station job. He worked at concrete construction; concrete floors, drives, walk; carpentry and as wall board installer.

On March 27, 1996, Respondent hired Shannon D. Smalley. Smalley did concrete construction and carpentry at Respondent’s Cooper Park Tennis Stadium job.3

On April 1, 1996, Respondent hired Lewis Eugene Warren. Warren did concrete construction and carpentry at Respondent’s Springfield Community Center job.

David Shannon Burns was hired on April 3, 1996. Burns worked at the Cooper Park Tennis Stadium where he did concrete construction and carpentry.4  Edward Hurley was hired on the Cooper Park Tennis Stadium on April 5, 1996. Hurley did carpentry work.

Respondent went on to hire three more employees later in April. It hired another employee in July, one in September and at least four more in October 1996.

As shown herein Leonard DeClue complained to both Terrence McCulloch and Anthony Twitty about the poor quality of work he was receiving from the other Cooper Park Tennis Stadium employees. Rick Shuler complained to Jim Carsel and Ken Shuler that he needed qualified workers on the Boatman’s Bank job.

Respondent was seeking qualified employees and Respondent actually hired applicants during the period after the nine alleged discriminatees submitted their applications on February 22, 1996.

Respondent pointed to its Exhibit 2 as showing that it received applications from a total of 25 applicants between January and July 1996, that were not hired. Those 25 applications included 16 that failed to show affiliation with a union.  In consideration of that argument and the evidence mentioned above, it appears that Respondent hired 13 employees from February 23 through July 1996; it received applications from 16 employees that showed no union affiliation during that period that it did not hire; and it received 9 applications from union affiliated employees on February 22, 1996, that it did not hire.

Respondent did not consider any of the union affiliated applicants for employment. None of those applicants were interviewed by Respondent either by phone or in person.

The record does not show whether the 16 other applicants were considered for employment.

The evidence clearly proved that Respondent was hiring during the period immediately following February 22. Despite Respondent’s argument I am unable to conclude that it did not discriminate against the alleged discriminatees. The record failed to show whether it considered hiring any of the 16 applicants not affiliated with the Union. On the other hand, none of the alleged discriminatees were considered for employment despite the fact that all were admittedly qualified to perform some of Respondent’s work.

As to whether Respondent knew of the source of the nine alleged discriminatees, Jim Carsel submitted nine applications to the receptionist at Respondent’s office on February 22. Jim Carsel announced they were with the Union and would like to apply with BCE.

Several of the applications submitted by Carsel on February 22 in a batch, included comments about the Union. Among other things, Jim Carsel’s application includes the notation, “Union organizer Member 311 Carpenters if hired I will try to organize BCE People on my own time.” Michael Rand’s application includes a comment “Carpenter for 19 years Local 978.” Ted Berch listed “Danny Hyde, Carpenter Union BA” as a reference. Robert Wirth included the comment, “member Carpenters Local 978 would like to organize on my time” on his application. Steven Wilson included on his application the comment “If hired I will work to my abilities and attempt to organize workers on my own time. I am a member of Carpenters Local # 978 Spfld. Mo.” Will Grooms wrote on his application, “I am a member of Carpenter’s 978 in Springfield, Mo. I intend to organize on my own time.” David Carson wrote on his application, “Trained union organizer - have taught classes in organizing. If hired I do intend to work to organize any non-organized workers during my own time. Member of Carpenters Local Union # 978.”

In view of the above I find that Respondent knew that the alleged discriminatees were affiliated with the Union and would attempt to organize Respondent’s jobs.

As to the question of animus, the record shows that Respondent harbored union animus. Respondent created the impression of surveillance of the employees’ union activities; it promulgated a rule against its employees talking about the Union; it interrogated employees about employees’ union affiliation and it warned that it would not go Union.

In determining the issue of animus I am mindful of the fact that all the 8(a)(1) activity came from Superintendent Leonard DeClue. Nevertheless, during the time when DeClue engaged in unlawful activity, Respondent through Superintendents Shuler and Younger were informing obvious union supporters that it was necessary to apply for work at Respondent’s main office.

If, as Respondent argues, it was unnecessary to apply at the office and if it was unlikely anyone would be hired unless they applied on a job, it appears that more than one of Respondent’s superintendents was involved in misleading prounion applicants into a job search that was unlikely to be successful. Therefore I am not persuaded that Respondent’s unlawful activity was limited to one superintendent. As to the issue of refusal to hire, it appears that others were also involved.

I find that the record also shows that Respondent used pretext in order to hide the true reason it did not hire or even consider hiring any of the alleged discriminatees. Fluor Daniel, Inc., supra; Adam Wholesalers, 322 NLRB 313 (1966). When the alleged discriminatees appeared at Respondent’s office on February 22, the receptionists gave them application forms. She subsequently thanked them for submitting applications. They were told by Respondent’s receptionists that their applications would be faxed to all Respondent’s jobs for consideration by the superintendents. She gave the applicants a list of jobs but told them that the phone numbers on that list were not correct.

Respondent Superintendent Rick Shuler told Jim Carsel and Ken Shuler that they needed to go to Respondent’s office to apply for a job. Robert Younger, another superintendent, told Union Representatives Carsel and Danny Hyde and applicant Robert Teitel the same thing.

Respondent, at a time before it learned that the applicants’ appearance at its office on February 22 was video recorded, submitted a letter of position to the NLRB Regional office. In that June 17, 1996 letter, Respondent pointed out that the February 22 applicants were told that BCE did not hire from its home office, that generally it did not take applications for hire at its home office and that field employees were hired by the respective project superintendents upon application made directly to the respective superintendent.

The video recording of the February 22 appearance of Jim Carsel and other applicants at Respondent’s office proved that Respondent was not truthful. The applicants were not told that BCE generally did not take applications for hire at its home office and they were not told that field employees needed to make application directly to the respective project superintendents.

I also find pretext in Respondent’s contentions that it did not consider hiring any of the alleged discriminatees because they were carpenters and Respondent did not have a need for carpenters. The record, as shown above, proved that some of the employees hired after February 22, actually worked as carpenters. Moreover, the record failed to show that a single superintendent actually determined not to consider one or more of the alleged discriminatees for that reason. Leonard DeClue testified that he was not seeking carpenters but he failed to show that he actually rejected a specific applicant for that reason. Actually, as shown herein, DeClue hired Anthony Twitty after Twitty told DeClue that he was a carpenter. Nevertheless, DeClue offered Twitty a job as a laborer. I find that Respondent’s claim that the nine alleged discriminatees were rejected because they were seeking carpenter jobs was a fabrication.

In fact the entire record shows that the applicants were not rejected because they were carpenters. Throughout the record Leonard DeClue was shown to complain about the incompetence of his employees. DeClue repeatedly praised one employee shown to be a carpenter, Terrence McCulloch. Additionally, Superintendents Rick Shuler and Bob Younger expressed their need for qualified help. That evidence illustrates that Respondent was not in a position of rejecting qualified help because the application failed to show with precision they were seeking an available job. As shown herein, Respondent’s own records showed that many of its employees engaged in carpentry. That was shown through Respondent’s use of employment security codes in some of its records.

Despite its claim to the contrary, Respondent did not routinely require applicants to appear at the jobsite. In fact employees were hired even though they did not appear at the jobsites. Those included William Baker and Ronnie Hardesty.

Moreover, it would not improve Respondent’s position to show that overt union organizers were not hired because they failed to apply with its superintendents in view of evidence that they were never told to apply at the respective jobs. Two of its superintendents told the union representatives including applicant Jim Carsel, that they needed to apply for work at Respondent’s office. If the alleged discriminatees were misled at a time after Respondent knew of their union affiliation, that action in itself should constitute a violation of Section 8(a)(1) and (3) of the Act.

General Counsel proved that Respondent was motivated to refuse to consider for hire and to hire the below named job applicants and that Respondent engaged in pretext in an effort to hide the fact that it took that action because of the alleged discriminatees union affiliation. I also find that Respondent failed to prove that it would have refused to consider or to hire the following applicants in the absence of protected and union activities. As shown above, the reasons given by Respondent were shown to be false. Manno Electric, Inc., 321 NLRB 278 fn. 12 (1996); Wright Line, 251 NLRB 1083 (1980), enfd. 662 F.2d 899 (1st Cir. 1981), cert. denied 455 U.S. 989 (1982); NLRB v. Transportation Management Corp., 462 U.S. 393 (1983):

 

        Jim Carsel               Michael Rand

        Ted Berch               Robert Wirth

        Larry Sowers          Kenneth Owens

        Steven Wilson         William Grooms

        Davis Carson