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.

International Brotherhood of Electrical Workers, Local Union No. 98 and TRI-M Group, LLC.  Case 4–CB–9713

August 31, 2007

DECISION AND ORDER

By Chairman Battista and Members
Kirsanow and Walsh

On April 10, 2007, Administrative Law Judge Paul Buxbaum issued the attached decision.  The Respondent filed exceptions, a supporting brief, and a reply brief, and the General Counsel and Charging Party filed answering briefs.

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 has decided to affirm the judge’s rulings, findings,1 and conclusions and to adopt the recommended Order.2

ORDER

The National Labor Relations Board adopts the recommended Order of the administrative law judge and orders that the Respondent, International Brotherhood of Electrical Workers, Local Union No. 98, Philadelphia, Pennsylvania, its officers, agents, and representatives, shall take the action set forth in the Order.

 

Dated, Washington, D.C.   August 31, 2007

 

 

                ______________________________________

            Robert J. Battista,                                 Chairman

 

                            ______________________________________

            Peter N. Kirsanow,                               Member

 

 

            ______________________________________

            Dennis P. Walsh,                                 Member

 

 

(Seal) National Labor Relations Board

 

Bruce G. Conley, Esq., for the General Counsel.

William T. Josem, Esq., of Philadelphia, Pennsylvania, for the Respondent.

Stephen J. Sundheim, Esq., of Philadelphia, Pennsylvania, for the Charging Party.

DECISION

Statement of the Case

Paul Buxbaum, Administrative Law Judge.  This case was tried in Philadelphia, Pennsylvania, on January 25, 2007. The charge was filed June 20, 2006,1 and the complaint was issued October 17. 2

The complaint alleges that the Union, through the actions of its agents, violated Section 8(b)(1)(A) of the Act by blocking an employee of the Company from entering a jobsite in order to perform a work task.  In addition, the complaint provides notice that the General Counsel seeks imposition of a broad remedial order requiring the Union to cease and desist from blocking employees’ ingress and egress from worksites or impeding employees from performing work duties, or in any other manner restraining or coercing employees in the exercise of their rights guaranteed by Section 7 of the Act.  The Union filed an answer denying the material allegations of the complaint. 

As described in detail in the decision that follows, I find that on June 16 the Union, through its agents, Raymond Della Vella, Craig Cummings, and Mike Quinn, blocked an employee of the Company, Sean Muth, from accessing a portion of a worksite and prevented that employee from performing a work task.  The Union’s conduct violated Section 8(b)(1)(A) of the Act.  I further conclude that the totality of circumstances demonstrates that the Union’s agents have a proclivity to violate the Act to the extent that an extraordinary remedial measure is required.  As a result, I concur in the General Counsel’s request for relief and recommend imposition of a broad cease-and-desist order.

On the entire record,3 including my observation of the demeanor of the witnesses, and after considering the briefs filed by the General Counsel, the Company, and the Union, I make the following

Findings of Fact

i. jurisdiction

The Charging Party, a Pennsylvania limited liability company with offices in Kennett Square, Pennsylvania, is engaged as an electrical contractor in the construction industry.  It annually performs services valued in excess of $50,000 outside the Commonwealth of Pennsylvania. The Union admits4 and I find that the Company is an employer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act, and that the Union is a labor organization within the meaning of Section 2(5) of the Act.

ii. alleged unfair labor practices

A.  The Facts

This case involves an incident occurring at the Genesis Health Care facility, a nursing home located on Edison Avenue in Philadelphia.  Starting in January 2006, Genesis underwent major renovation, including installation of a new electrical distribution system.  The general contractor for this project was Delran Builders Company, Inc.  Their project superintendent was Steve Herman.  The electrical subcontracting work was performed by the Company.  Their foreman at this location was Joseph Prego.  The Company’s work force is not represented by any labor organization.

Beginning in early April, the Union picketed the Genesis worksite, contending, in the words of its placards, that the Company was “Destroying Building Industry Standards” by “Not Observing Our Wage and Benefit Standards.”  (GC Exh. 6.)  At the commencement, picketing was conducted on a daily basis.  Once other unions began similar activities at the site, the Union generally restricted its own activities to Fridays.  Picketing was conducted on approximately 20 Fridays, from 7 a.m. until 2 p.m.  The person responsible for directing this activity was Raymond Della Vella.  He has been a business representative and organizer for the Union since 1998.  Della Vella confirmed that, in the words of counsel for the General Counsel, he was “the official designated by Local 98 to be in charge of the picketing” at the Genesis Health Care construction project site.5  (Tr. 23.)  

Because it is important to an assessment of one of the key issues in this case, it is necessary to describe the location, manner, and purpose of the Union’s picketing activities.  The Genesis facility has a parking lot with two entrances.  Since the nursing home continued to operate during the renovations, a variety of people entered and left the property through those entrances, including employees of Genesis, delivery persons, and employees of the various contractors engaged in the construction activities.6 

Of the two entrances to the facility, it is the eastern one that is involved in this case.  That entrance has a wide section of concrete connecting Edison Avenue to the Genesis parking lot.  This concrete entryway crosses the pedestrian sidewalk.  The sidewalk continues past the entrance for a short distance.  It comes to an end at a wooded area traversed by a creek.  At this place, Delran stationed dumpsters for storage of construction debris.  The outer dumpster is located parallel to the sidewalk and its end is adjacent to the woods.  All of this is well illustrated in the photographic record that forms a large part of the documentary evidence in this case.  In particular, Herman testified that he took a series of photos during the incident at issue.  These pictures constitute General Counsel’s Exhibits 6, 7, and 9–15.7  Of these photos, General Counsel’s Exhibit 12 contains the best view of the geography that is involved in the parties’ controversy.  In the foreground of the photo, one can see a portion of the wide piece of concrete that forms the eastern entrance to the facility.  Beyond that, the sidewalk extends to the wooded area, where it terminates.  Parallel to the sidewalk is the outermost of the dumpsters.

Della Vella testified about the manner and purpose of the Union’s picketing.  He reported that the Union located pickets at each of the entrances to the facility.  Typically, two pickets would be placed at each of those entrances.  Significantly, Della Vella explained that the reason for the picketing activity was to publicize the Union’s dispute with the Company by enabling persons who were driving onto the facility’s property to read the placards carried by the pickets.  Thus, the evidence demonstrated that the Union’s pattern of conduct was to station a set of two pickets at the eastern entrance to the facility in order to bring to the attention of the interested public the nature of its dispute with the Company.  

On Friday, June 16, the Union engaged in this customary picketing activity.  As was its practice, the Union had notified the Civil Affairs Division of the Philadelphia Police Department that it would be picketing on that day.  The department assigned officers Edward Braceland and Ira Watterson to observe the situation.  They parked their vehicle in the facility’s lot, adjacent to the dumpsters.8

Della Vella testified that pickets were placed “at both entrances” to the Genesis facility.  (Tr. 111.)  The two pickets at the east entrance were union members Cummings and Quinn.  Della Vella was stationed across the street.  As he described it, “I was keeping an eye on both picket signs and I was taking care of . . . general things I had to do.”  (Tr. 111.)

Sean Muth testified that he is a longtime employee of the Company.  He is not a supervisor, nor is he a member of any labor organization.  He works as an electrician and sometimes operates a backhoe.  At approximately 1 p.m. on June 16, Muth placed a load of construction debris in the bucket of a backhoe.  He planned to drive the backhoe out onto Edison Avenue so that he could approach the dumpster and drop his load into it.  He testified that he was required to use this route because it afforded the only practical access to the dumpster that would permit him to properly dispose of his load. 

Muth testified that he had a coworker stop traffic on Edison Avenue so that he could “swing out.”  (Tr. 92.)  As he explained, he “went to swing out and pulled up towards the dumpster and the pickets walked in front of me.”  (Tr. 92.)  Because the movements of the pickets are a key aspect of this case, it is important to note that Muth was repeatedly questioned on this point.  He clearly testified that, prior to the commencement of the incident, the pickets had been stationed “towards the driveway” leading into the parking lot.  (Tr. 101.)  As he phrased it, “[t]hey walked down in front of the dumpster when I got turned towards it.”  (Tr. 94.)  The following additional discussion precisely illustrates Muth’s contention regarding the pickets’ movements:

 

Counsel:     Before the incident started when you got in the backhoe with the debris, where were the pickets standing and perhaps you can show us on the General Counsel’s Exhibit GC-8?

 

Muth:          More towards this end of the dumpster.

 

Counsel:     In other words[,] towards the driveway?

 

Muth:          Yes.

 

Judge:          So[,] as we’re looking at it, that’s towards the right of the  dumpster? 

 

Muth:          Yes.

 

Counsel:     [T]hen a[s] you went into the street to approach the dumpster to make the dump, did the pickets then move in front of the backhoe so that they were between—so that they were now between the backhoe and the dumpster?

 

Muth:          Yes, they walked down from there to that point.

 

Counsel:     They walked from the original position which was to the right of the dumpster so that they were no[w] positioned directly in front of the dumpsters so that you could not make the dump?

 

Muth:          That’s correct, in front of the machine.  [Tr. 101–102.]

 

On this point, Della Vella’s testimony stands in sharp contrast to that of Muth.  I asked him, “[w]hat about immediately prior to when the backhoe first came out onto the street, where were [the pickets] then?”  He responded that, “[t]hey were in front of the dumpster.”  (Tr. 126.)  This assertion forms the basis for Della Vella’s explanation for what occurred next.  He concedes that he instructed the pickets to maintain a position in front of the dumpster.  He described his reasoning as follows:

 

I felt that the backhoe was interfering with us.  We had been on that sidewalk standing in that very position for months and we thought we were being interfered with, that we weren’t interfering with anybody, we just thought we were being harassed.  [Tr. 116.] 

 

In other words, the Union’s contention is that its pickets had been standing in front of the dumpster when Muth first drove out onto the street.  According to this version, Muth’s actions would have had the effect of dislodging the pickets from their preexisting station in front of the dumpster.

There are a number of reasons why I credit Muth’s account and discredit that of Della Vella.  First and foremost, Muth testified in an impressively calm, dispassionate manner that left me with a sense of his fundamental neutrality in this dispute.  Second, although Della Vella claims that the pickets were standing in front of the dumpster when Muth arrived, he earlier testified that, in the phrasing of counsel, the two pickets were “picketing at that east entrance.”  (Tr. 111.)  In other words, they would have been standing at some distance from the dumpster.  Furthermore, the placement of the pickets at the entrance comports with logic and common sense.  The purpose of the picketing was to alert the public about the terms of the Union’s dispute with the Company, particularly those members of the public with a potential interest in the matter, such as employees of the firms performing the construction work and persons having business with the nursing home.  Picketing at the entrance is designed to facilitate this purpose.  Picketing at the dumpster would be comparatively ineffective at accomplishing this objective.  That locale is at the edge of the property, adjacent to woods and a creek.  It simply defies logic to believe that the Union would choose the dumpster as a primary locus for its pickets.9 

I also note that the precise location of the two pickets as of the commencement of this incident is key to the Union’s defense in this case.  Despite this, the Union did not call as witnesses either of the pickets themselves.  Cummings and Quinn are members of the Union and no explanation was offered as to why their testimony was not presented.10  Because one would have reasonably expected that their testimony would have supported Della Vella’s contentions, the unexplained failure to produce them as witnesses leads me to draw an adverse inference.  See Daikichi Sushi, 335 NLRB 622 (2001), enf. 56 Fed. Appx. 516 (D.C. Cir. 2003) (adverse inference drawn against employer who failed to produce testimony from the only management official present at a key meeting) and NLRB v. Iron Workers, 124 F.3d 1094, 1101 (9th Cir. 1997) (Board’s “well established” use of adverse inference for failure to produce testimony was properly applied to a respondent labor organization). 

In sum, my finding that Muth’s account is credible is based on my assessment of his demeanor and motivation as reinforced by the contradiction in Della Vella’s testimony, the unexplained absence of other pertinent testimony, and the inherent logic of the situation.  I conclude that, on observing Muth’s approach in the backhoe, the pickets moved from their prior station at the east entrance and assumed a new position directly in front of the dumpster.

General Counsel’s Exhibits 7 and 12 clearly illustrate the situation as it existed once the pickets moved into place in front of the dumpster.  In these photos, union members Cummings and Quinn, accompanied by Della Vella, are shown standing directly between the backhoe’s bucket and the dumpster.11  There is no dispute regarding the remaining events.  Muth testified that he waited in his machine.  After 5 to 10 minutes, his foreman, Prego, arrived.  Prego instructed him to return the backhoe to the facility’s parking lot.  He complied.  At this juncture, Herman also arrived on the scene.  He told the police officers that Muth needed to dump the debris.  Officer Watterson told him to proceed.  He instructed Muth to start the backhoe.  Prego stopped the traffic on Edison Avenue.  Muth moved the backhoe into position.  At that point, Cummings and Quinn were still posted in front of the dumpster.  Della Vella had moved away and was standing on a bridge over the creek talking on his cell phone.  Herman asked the pickets to move.  Cummings told him “to go talk to the boss and he pointed down to the picketer that was over at the bridge talking on his cell phone.”12  (Tr. 69.) 

According to Herman, at this point Della Vella approached and told the police to instruct Herman to “shut up.”  (Tr. 69.)  He then joined the other pickets in front of the dumpster.  Officer Watterson told Herman he was going to instruct the pickets to move.  He had a conversation with Della Vella that lasted “a few minutes.”  (Tr. 71.)  Watterson directed Muth to move the backhoe forward.  Muth complied, but was again required to stop because the pickets did not step out of the way.  The officer again instructed Muth to move forward.  Muth inched another foot or so closer to the dumpster.  After some minutes, Della Vella “directed his guys to move away.”  (Tr. 73.)  Watterson instructed Muth to make his dump and Muth complied.  There were no further problems at the site on that day.

As may be anticipated whenever multiple witnesses provide estimates of elapsed time, there was some variance in the description of how long the incident lasted.  Prego estimated that 15 to 20 minutes elapsed between the time he first observed the pickets blocking the dumpster and the end of the episode.  Herman reported that “about 20 minutes elapsed.”  (Tr. 80.)  Muth testified that it was between 30 to 35 minutes from his first attempt to dump until he was able to accomplish his mission.  Della Vella estimated that the entire incident took “no more than ten minutes.”  (Tr. 119.)  Under questioning by counsel for the Company, Della Vella was asked whether “you and the other two pickets refused to move from your position in front of the dumpster for at least, you said five to ten minutes, so that the dumpster could not be reached or gotten to by the backhoe, correct?”  He responded, “[t]hat’s correct.”  (Tr. 127.)  Ultimately, it must be recalled that only two individuals who testified were present throughout the events, Della Vella and Muth.  For reasons already discussed, I credit Muth’s account and find that the incident, in its entirety, last approximately one-half an hour.   

To summarize, I have found that an employee of the Company, Muth, was engaged in a work task requiring that he bring his backhoe into position to dump debris into a dumpster.  The Union’s pickets observed Muth maneuvering into place.  They moved from their prior station at the parking lot entrance to a new location designed to block Muth’s access to the dumpster.  They remained in that blocking position for a period of approximately 30 minutes before stepping aside to allow Muth to complete his task. 

B. Legal Analysis

The General Counsel contends that the Union violated Section 8(b)(1)(A) of the Act when its pickets, in the words of counsel’s opening statement, “moved and stationed themselves on the public sidewalk running parallel to the dumpster directly in front of the path of the backhoe.”  (Tr. 11.)  The pertinent portion of the statute makes it an unfair labor practice for a labor organization or its agents “to restrain or coerce employees in the exercise of the rights guaranteed in Section 7.”13  The Board’s venerable test for application of this standard is whether the conduct in question is “reasonably calculated to coerce anti-union or non-union [employees] in the exercise of their right, under the amended Act, to refrain from joining the Union.”  Ladies Garment Workers (Seamprufe, Inc.), 82 NLRB 892, 894 (1949), enf. 186 F.2d 671 (10th Cir. 1951), cert. denied 342 U.S. 813 (1951).  See also Randell Warehouse of Arizona, 347 NLRB No. 56, slip op. at 6 (2006) (describing the standard as “reasonable tendency to coerce employees”). 

Over the years, the Board has consistently found that the blocking of access to an employee’s workplace constitutes unlawful restraint and coercion.  Early on, it held that pickets who placed themselves in the path of employees’ vehicles attempting to enter an employer’s plant violated Section 8(b)(1)(A).  Longshoremen ILWU Local 6 (Sunset Line & Twine Co.), 79 NLRB 1487, 1506 (1948).  Similarly, blocking the door of a facility so as to prevent an employee from entering was also found to violate that Section.  Metal Polishers, Local 67, 200 NLRB 335 (1972).  Much more recently, this principle was again upheld by the Board while affirming a judge’s observation that “efforts to prevent employees from reporting to work by impeding access to an employer’s facility [are] proscribed by this Section.”  Service Employees Local 525, 329 NLRB 638, 685 (1999), affd. 52 Fed. Appx. 357 (9th Cir. 2002).  Furthermore, the prohibition against blocking access is not limited to conduct directed against employees who are arriving for, or departing from, work.  The Board has also found it unlawful for pickets to block “employees from entering the [employer’s] facility to perform assigned tasks.”  Mine Workers District 17 (Dehue Coal), 275 NLRB 715 (1985).  

In applying these principles, the Board has been clear that the mere absence of violence is not a defense.  Thus, in Carpenters (Society Hill Towers Owners’ Assn.), 335 NLRB 814, 815 (2001), the Board reversed a judge’s finding of no violation premised on the fact that there was “no hint of violence” in the union’s conduct.  In a case involving conduct similar to that at issue here, the Board (Metal Polisher Local 67, supra at fn. 10) held that:

 

The absence of physical violence does not lessen the restraining effect of Respondent’s conduct.  Here . . . [t]he car drivers were faced with the choice of running down the pickets, at the risk of inflicting serious injury, or driving away.  This interposition of passive force to prevent employees from going to work is, we believe, a form of restraint proscribed by Section 8(b)(1)(A). 

 

Metal Polishers, Buffers, Intl. Local 67, 200 NLRB 335 (1972), at fn. 10. See also Service Employees Local 525, supra at 685 (nonviolent conduct that includes prevention of access to employer’s facility violates the Act).

The Board has also held that the short duration of prohibited conduct of the type at issue in this case is not a defense.  See Longshoremen ILWU Local 6 (Sunset Line & Twine Co.), supra at 1506 (preventing nonstriker’s cars from entering parking lot “for only a short period of time” constituted restraint and coercion within the meaning of Section 8(b)(1)(A)).  Indeed, the Board has reversed a conclusion that “a delay of one to five minutes under peaceful circumstances hardly constitutes blocking or barring ingress so as to constitute a violation of the Act.”  Instead, the Board held that, “[s]uch a construction is at variance with established Board law.”  Metal Polishers, supra at 336.  Counsel for the Union argues that the short duration and nature of the conduct in this case rendered it “de minimis.”  (R. Br. at p. 5.)  This is premised on his acceptance of Della Vella’s testimony that the incident lasted no more than 10 minutes.14  Having found that the entire blocking episode had a duration of approximately 30 minutes, it cannot be seriously contended that it was of too short a duration to be legally cognizable as an unfair labor practice.  

Finally, the Board has declined to withhold administrative action simply because the conduct at issue implicated the interests of state or local law enforcement.  In Service Employees District 1199 (Staten Island University Hospital), 339 NLRB 1059, 1062 (2003), the Board rejected a contention that the employer should have “looked to a state court lawsuit or to the police for assistance, rather than to the Board.”  As a result, the fact that the Philadelphia police successfully defused the situation in this case is immaterial. 

With this background in mind, it is readily apparent that the Union’s conduct in moving from a position by the entrance to the Genesis facility to a location clearly intended to preclude Muth from accessing his worksite to complete a job task and in maintaining that blocking position for approximately 30 minutes constituted the sort of restraint and coercion made unlawful by Section 8(b)(1)(A).  Muth was presented with precisely the type of situation discussed by the Board in Sunset Line & Twine Co., supra.  He could either take the risk of inflicting serious bodily injury on the pickets or refrain from accessing the dumpster to complete his task.  The imposition of such a dilemma on a nonunion employee is the sort of restraint and coercion prohibited by the Act.15  

Conclusion of Law

By moving its pickets into a position designed to preclude an employee of the Company from accessing his worksite in order to complete a work assignment and by maintaining that blocking position for approximately 30 minutes, the Union has engaged in an unfair labor practice affecting commerce within the meaning of Section 8(b)(1)(A) and Section 2(6) and (7) of the Act.

Remedy

Having found that the Union has engaged in an unfair labor practice, I find that it must be ordered to cease and desist and to take certain affirmative action designed to effectuate the policies of the Act.  The appropriate relief includes the imposition of a cease-and-desist order and the requirement for the posting of a notice. 

In his complaint, the General Counsel served notice that he would be seeking a broad order requiring the Union to cease and desist from blocking employees’ ingress and egress to jobsites, impeding employees from performing services at their jobsites, or, in any other manner restraining or coercing employees in the exercise of their rights guaranteed by Section 7 of the Act.  Because it both broadens the types of misconduct enjoined and the scope of coverage to include employees of all employers, this proposed remedy goes beyond the relief that is typically granted.

The Board’s power to impose a remedy for unfair labor practices stems from the language of Section 10(c) of the Act, which provides that, upon a finding that a respondent has committed an unfair labor practice, it shall issue “an order requiring such person to cease and desist from such unfair labor practice, and to take such affirmative action . . . as will effectuate the policies of this Act.”  The Supreme Court has observed that this is a Congressional grant of authority that is broad and yet rather vague.  The Court held that, “at a minimum it encompasses the requirement that a proposed remedy be tailored to the unfair labor practice it is intended to redress.”  Sure-Tan v. NLRB, 467 U.S. 883, 900 (1984).  Put another way, the Court has instructed that the validity of any remedial measure imposed by the Board must be “examined in light of the appropriateness in the circumstances of [the] case.”  NLRB v. Mine Worker District 50, 355 U.S. 453, 458 (1958).

The Supreme Court has also addressed the standards for imposition of the precise type of relief being sought in this proceeding.  In NLRB v. Express Publishing Co., 312 U.S. 426, 437 (1941), it held that the justification for a broad order must be that its provisions “bear some resemblance to that which the [respondent] has committed or that danger of their commission in the future is to be anticipated from the course of his conduct in the past.” 

Applying the Court’s teachings, the Board has developed a test for gauging the appropriateness of any request for a broad order.  In Hickmott Foods, 242 NLRB 1357 (1979), a case involving violations of the same section of the Act as found here, the Board held that:

 

[A broad] order is warranted only when a respondent is shown to have a proclivity to violate the Act or has engaged in such egregious or widespread misconduct as to demonstrate a general disregard for the employees’ fundamental statutory rights.  Accordingly, each case will be analyzed to determine the nature and extent of the violations committed by a respondent so that the Board may tailor an appropriate order.  [Footnote omitted.] [Id. at 1357.]

 

It concisely summarized its test by noting that “repeat offenders and egregious violators” would be subject to imposition of a broad cease-and-desist order.  242 NLRB at 1357.  Very recently, the Board has provided an additional commentary on its Hickmott Foods standard.  In Five Star Mfg., 348 NLRB No. 94, slip op. at 1 (2006), it noted that, while considering imposition of a broad order under Hickmott, “the totality of circumstances” must be examined to determine whether the respondent’s behavior manifests, “an attitude of opposition to the purposes of the Act to protect the rights of employees generally, which would provide an objective basis for enjoining a reasonably anticipated future threat to any of those Section 7 rights.”  (Internal quotation marks and citation omitted.) 

Turning to the application of these principles, I begin by noting that the General Counsel and the Company do not contend, and the evidence does not establish, that the violation committed in this case, standing alone, was of such an egregious nature as to justify imposition of a broad order.  In fact, the violation, while clearly implicating important Section 7 rights, was confined to a single episode and employed passive force rather than any form of overt threat or violence.  Furthermore, following intervention by local law enforcement authorities, the Union terminated its unlawful behavior.  Thus, imposition of broad relief must be justified, if at all, by an overall determination of whether the Union is a recidivist offender of such magnitude as to require an extraordinary response.  In order to make this assessment, it is necessary to provide a detailed account of the Union’s past behavior.

The record contains the following undisputed documentation regarding the Union’s past misconduct and Della Vella’s unlawful activities on its behalf, with specific focus on those incidents involving behavior similar to that which occurred in this case.16  In 1996, the General Counsel filed a series of complaints alleging that the Union had engaged in a variety of unfair labor practices, including the blocking of employees’ ingress to a facility of Bell Atlantic-Pennsylvania, Inc., and blocking employees’ ingress to two separate construction sites of Lucent Technologies, Inc.  (GC Exh. 2(a).)  On July 18, 1997, the Board entered an Order premised on a settlement stipulation providing that the Union cease and desist from “[b]locking or impeding the ingress of employees to facilities” of the two employers.  The order also directed the Union to cease and desist from threatening employees in various manners, videotaping them, or “[p]ushing, surrounding, bumping or spitting on employees.”  It also prohibited any like or related violations of the Act directed against employees of Bell or Lucent.17  (GC Exh. 2.)  On November 25, 1997, the United States Court of Appeals for the Third Circuit entered a judgment enforcing the Board‘s Order.  (GC Exh. 3.)   

On July 7, 1998, an administrative law judge issued a decision finding that, in March 1997, the Union, through its agents, violated Section 8(b)(1)(A) of the Act by physically assaulting employers and destroying their property in the presence of employees and by pushing an employee against a wall.  The judge also found other violations of Section 8(b) involving threats and inducements to an employer to cease doing business with another entity and unlawful picketing activities designed to accomplish the same objective.  Many of these additional unlawful acts were found to have occurred in October 1997, just 3 months after the Board had entered its order in the previously cited case.  In her decision, the judge also granted the General Counsel’s request for a recommendation of a broad cease-and-desist order as to future violations of Section 8(b)(4)(i)(B) and (ii)(B).  She explained her reasoning as follows, Electrical Workers Local 98 (Telephone Man), 327 NLRB 593, 602 (1999):

 

Respondent’s unlawful actions toward 10 separate neutral employers in a 19-month period, involving picketing, threats to picket, and work stoppages at six locations in the Philadelphia area, demonstrates Respondent’s proclivity for violating the Act and its general disregard for the fundamental rights of employees and neutral employers.  A narrow order, confined to the instant case, would not sufficiently deter further misconduct.  I therefore recommend that the Board issue a broad order requiring the Respondent to cease and desist from infringing in any other manner on rights guaranteed employees by Section 7 of the Act.  [Citations omitted.]

 

The judge’s proposed broad order enjoined the Union from restraining or coercing employees of any employer by engaging in various specified forms of misconduct.18  On February 12, 1999, the Board affirmed the judge’s findings and conclusions and adopted her recommendations, including the broad cease-and-desist provisions.  Id. at 593.  On September 29, 2000, the United States Court of Appeals for the Third Circuit issued a judgment enforcing the Board’s broad order.  (GC Exh. 4.)

Just months after the Board issued its decision in Electrical Workers Local 98 (Telephone Man), above, the Union engaged in a series of unlawful acts of the same nature as those alleged in this case.19  In May 1999, it prevented employees of Wohlson Construction Company from entering or leaving a jobsite.  In the following month, Della Vella, on behalf of the Union, threatened to block ingress and egress of a facility of the United Parcel Service.  Consistent with these threats, union pickets prevented vehicles from entering and leaving that facility.  Two months later, in conduct virtually indistinguishable from the unlawful act committed by the Union in this case, an official of the Union drove his automobile into a position so as to block an employee of MCF Services, Inc., from using a forklift to dump waste into a dumpster.

In January 2000, the Union, through Della Vella, engaged in unlawful blocking activity at a worksite of Swartley Brothers Engineers, Inc.  Shortly thereafter, in February 2000, Della Vella, again acting as the Union’s agent, gained unauthorized access to a secure worksite of Swartley Brothers.  The worksite was at a facility of Verizon Wireless Corp.  When asked to leave by a Verizon employee, Della Vella “struck the Verizon employee in the face.”  Electrical Workers Local 98 (Swartley Bros. Engineers), 337 NLRB 1270, 1271, and 1273 (2002).  On September 12, 2002, the Board issued a decision in this Section 10(k) case involving the Union.  Although this involves a different sort of proceeding against the Union, it is relevant here for a number of reasons.  In Swartley, the Board issued a broad order based on its determination that, “Local 98 has a proclivity to engage in wrongful conduct in order to obtain work similar to the work in dispute in this case.”  Id. at 1273.  In reaching this conclusion, the Board observed:

 

In this regard, we note not only that the record in this case supports the conclusion that Local 98 has a proclivity to engage in wrongful conduct in order to obtain disputed work, but also that the record in other recent cases before the Board underscores this as well.  See, e.g., Electrical Workers Local 98 (Total Cabling Specialists), 337 NLRB 1275 (2002); Electrical Workers Local 98 (NFF Construction, Inc.), 332 NLRB 1262 (2000); Electrical Workers Local 98 (Honeywell, Inc.), 332 NLRB 526 (2000); Electrical Workers Local 98 (AIMM, Inc.), 331 NLRB 1075 (2000); Electrical Workers Local 98 (Kastle Security), 324 NLRB 728 (1997); Electrical Workers Local 98 (LaSalle University), 324 NLRB 540 (1997); Electrical Workers Local 98 (Lucent Technologies), 324 NLRB 226 (1997) (Board issues broad areawide award against Local 98 because of likelihood of dispute’s recurrence and union’s proclivity to violate the Act); and Electrical Workers Local 98 (Lucent Technologies), 324 NLRB 230 (1997) (Board issues broad areawide award against Local 98 because of likelihood of dispute’s recurrence and union’s proclivity to violate the Act). [Id. at fn. 7.] 

 

This case is also significant because the Union’s misconduct was committed by Della Vella.  Finally, it is noteworthy because the Board took pains to report that, based on its conclusion that the misconduct also violated the broad order that it had issued in Electrical Workers Local 98 (Telephone Man), supra, it was pursuing civil contempt proceedings against “both Local 98 and Della Vella.”  337 NLRB at 1273 fn. 7.  It concluded by emphasizing that, “[t]he Board has now determined that Local 98’s conduct underlying the instant case is in direct contempt of the Third Circuit’s 2001 consent order.”  Id.

Approximately a year later, on September 16, 2003, the Third Circuit entered a consent order implementing the parties’ stipulation resolving the contempt proceedings against Local 98 and Della Vella.  As part of that order, Della Vella was required to pay to the Board the sum of $5000 “representing a compromised amount of fines, compensatory damages and/or attorneys’ fees caused by Della Vella’s failure to comply with the picketing and other provisions of the Court’s prior order.”  (C.P. Exh. 1, consent order, p. 1.)  The Court further directed that the amount paid by Della Vella could not be reimbursed to him by the Union.  It also required the posting of a notice to be “signed by appropriate officers on behalf of Local 98, and by Raymond Della Vella individually.”  (C.P. Exh. 1, consent order, p. 3.)  Furthermore, it required that the Union convene a “special meeting of business agents, organizers and officers” at which the notice was to be read aloud.  (C.P. Exh. 1, consent order, p. 3.)  Lastly, it established certain procedures designed to provide assurance that any future picketing activity by the Union would be lawful. 

While all this litigation was underway, the General Counsel was also prosecuting another highly relevant case against Local 98.  On June 23, 2000, an administrative law judge issued a decision in Electrical Workers Local 98 (MCF Services), 342 NLRB 740 (2004).  The judge’s detailed description of the Union’s conduct is significant for two reasons.  First, some of that conduct mirrors the Union’s behavior in the case before me.  For example, as I indicated earlier, the judge reported that an employee:

 

[He] testified that as he drove his forklift to the dumpster [Local 98 Organizer] Browne drove his vehicle, a black Lincoln Continental, between the forklift and the dumpster . . . Browne kept his car in the same blocking position for about 15–30 minutes, thus preventing him from completing his chore, after which he drove away.  [Id. at 751.]

 

The judge credited this testimony and found a violation of Section 8(b)(1)(A).20  He also found additional violations based on misconduct that was similar in nature to the events that transpired here, including blocking activity by pickets that prevented an employee from “reentering the jobsite after he had exited momentarily to retrieve something from his truck” and preventing employees from driving their vehicles into the entrance to a worksite.  342 NLRB at 757 and 758. 

The second reason that MCF Services is of significance to the issue under consideration by me is that, once again, one of the Local 98 officials involved in unlawful picketing activities was Della Vella.  As the judge described an employer’s representative:  

 

McGlure asked if Della Vella was going to let any of UPS’ vehicles in or out of the Oregon [Pennsylvania] facility, the latter replied, “No way, no f–king thing’s coming in and out of this building.”

 

. . .

 

Consistent with Della Vella’s remarks, certain vehicles seeking to enter and leave the Oregon facility were in fact prevented from doing so by Local 98 pickets.  [342 NLRB at 760.]

 

The judge found this conduct to be unlawful and formally concluded that, “Local 98 has further violated Section 8(b)(1)(A) of the Act by blocking the egress and ingress of employees and vehicles at the UPS and PPH jobsites.”  Id. at 762. 

As in Telephone Man, the General Counsel requested that the judge recommend a broad order directed at potential future violations of Section 8(b)(4)(i) and (ii)(B) of the Act, but did not seek such relief as to possible misconduct in violation of Section 8(b)(1)(A).  The judge, citing the Union’s past history, granted the request, noting that:

 

As evident by its conduct here, Local 98 has not changed its ways.  Indeed, Local 98 has, by its conduct herein, demonstrated a deliberate and near contemptuous disregard for the Board’s processes and remedial orders, and has again shown its proclivity to violate the Act a well as a general disregard for the fundamental rights of employees and neutral employers.  In these circumstances, a broad order is both appropriate and necessary.  [Footnote omitted.]  [342 NLRB at 763.] 

 

On July 30, 2004, the Board affirmed, in pertinent part, the judge’s findings and conclusions, including the finding that “Browne used his vehicle to block [an employee] from operating a forklift for about 15–30 minutes.”  [Footnote omitted.]  342 NLRB at 741.  In addition, the Board adopted the judge’s proposed order.  That order required that Local 98 cease and desist from:

 

Interfering with, restraining, or coercing employees of employers performing work at the Cheltenham, PPH, and UPS jobsites, or of any other employer, by threatening them with physical harm, photographing them as they enter and leave their workplace, and blocking them and their vehicles from entering or leaving their jobsites or, in any other manner interfering with the rights guaranteed to employees by Section 7 of the Act.  [342 NLRB at 763.] 

 

On September 14, 2006, the Board petitioned the Third Circuit for enforcement of this order.  (GC Exh. 5.)  That matter is pending.21

With this dismal record of misconduct as background, I must now determine whether the Union has manifested a proclivity to violate the Act because of an attitude among its officials of opposition to the purposes of the Act and a hostility to the Section 7 rights of nonunion or anti-union employees.  See Hickmott Foods and Five Star Mfg., supra.  The Board has repeatedly found that the Union’s officials have a proclivity to violate a range of provisions of the Act, including participation in conduct that is essentially identical to the misconduct proven in this case.  In decisions upheld by the Board, two judges found that the Union had a “general disregard for the fundamental rights of employees.”  See, The Telephone Man, supra, 327 NLRB at 602, and MCF Services, supra, 342 NLRB at 763, both employing identical language.  In addition, the judge in MCF Services noted that the Union had “a deliberate and near contemptuous disregard for the Board’s processes and remedial orders.”  342 NLRB at 763. 

In response, counsel for the Union cites significant Board precedents establishing the Board’s general unwillingness to impose broad relief based on prior acts of misconduct that occurred many years earlier.  See:  Wolverine World Wide, Inc., 243 NLRB 425 (1979) (misconduct committed 6 to 14 years earlier is too remote to warrant broad order); Operating Engineers, Local 12 (Hensel Phelps), 284 NLRB 246 fn. 2 (1987) (similar); Service Merchandise Co., 299 NLRB 1125 fn. 7 (1990) (similar); Teamsters Local 456 (Peckham Materials), 307 NLRB 612 fn. 4 (1992) (similar).  While it has not articulated a precise time limit, the Board appears to draw the appropriate demarcation at the passage of approximately 4 years without evidence of misconduct.  Thus, in Plumbers Local 388 (Daily Heating), 280 NLRB 1260, 1280 (1986), it affirmed a judge’s conclusion that a union’s “hiatus in engagement of any illegal activity for 4 to 5 years . . . is a significant intervening period of indicated compliance with the statutory scheme.”  Similarly, the Board declined to impose a broad order in Sheet Metal Workers, Local 19 (Delcard Associates), 328 NLRB 80 (1999), noting that, although the union had demonstrated a past proclivity to violate the Act, “the Respondent apparently has not violated the Act in any similar respect in the intervening four years.”  (Footnote omitted.) 

In the case before me, the misconduct occurred on June 16, 2006.  The most recent related prior misconduct by both the Union in general and Della Vella in particular was found to have taken place on January 4, 2002.  Electrical Workers Local 98 (Swartley Bros.), supra at 1271.  This represents a period of 4-1/2 years of apparent compliance with the Act.  While representing a close question, I conclude that the passage of this period of time insulates the Union from a finding of proclivity based solely on a history of prior misconduct.22

I, nevertheless, conclude that it is necessary and appropriate to recommend the imposition of a broad order in the unique circumstances of this case.  I do so for two reasons.  First, I take note that labor organizations, just as corporations, are not independent actors possessed of their own free will.  Rather, they operate in the world through the decisions of the human beings who hold the power to direct and control them.23  I have considered this reality in assessing the proper remedy for this violation.  I recognize that it would be unfair to overemphasize the meaning of old violations by such an organization in the absence of indications that the attitudes underlying such violations persist among the persons who currently manage their affairs.  The converse of such a recognition also applies with equal force.  It is particularly appropriate to hold such an organization to account for the harmful attitudes of its officials where the evidence shows continuity of tenure and behavior by those same individuals.  Thus, it is of particular probative weight that the “boss” of the pickets who directed and controlled the activities that prevented Muth from performing his job was the same person who has a substantial prior history of violations of the Act.  (Tr. 69.)  The record demonstrates that the Board’s remedial measures have not led to a change of attitude on the part of Della Vella.  Nor have they resulted in a change in the Union’s decision to entrust Della Vella with the authority and responsibility to supervise its picketing activities.  This is a powerful argument for imposition of the strongest measures that can reasonably be calculated to deter any further related misconduct by the Union and protect the Section 7 rights of employees.

In addition, I find it highly significant that Della Vella’s recidivist conduct occurred less than 3 years after the Third Circuit’s entry of a consent order against him.  That judgment provided a broad range of rather inventive remedies designed to achieve future compliance with the law.  In addition to the punitive sanction, it included strong remedial measures intended to educate the Union’s leaders regarding the manner in which picketing activities must be conducted so as to protect the fundamental rights of employees under the Act.  As counsel for the General Counsel observes:

 

Respondent and Della Vella were also on notice as a result of the Consent Order issued in 2003, even though the conduct underlying that matter did not involve issues of Section 8(b)(1)(A) of the Act, that they still [had] to take precautions in conducting any future picketing. 

 

(GC Br. at p. 20.)  Alas, these measures appear to have been less than fully effective.

As I have noted earlier, the Board has very recently stressed the need for a comprehensive assessment of the totality of circumstances when deciding whether a respondent’s attitude of hostility to the purposes of the Act provides a proper basis for imposition of broad relief.  Five Star Mfg., supra.  In my view, the passage of less than 3 years since the imposition of a contempt judgment against the Union, and against Della Vella personally, before the commission of further picketing misconduct by them constitutes a compelling circumstance requiring broad relief.  In this regard, I agree with counsel for the General Counsel, who cites Electrical Workers Local 3 (Teknion, Inc.), 329 NLRB 337 (1999).  In that case, the Board relied “particularly” on the fact that the respondent union had consented to entry of judgment against it by the Court of Appeals and, yet, had committed another related violation “just a little more than 2 years later.”  Id. at fn. 2.  Standing alone, this history was found to “sufficiently demonstrate[ ] that the Respondent has a proclivity for violating the Act, and thus warrants our adoption of the judge’s recommended broad order.”  Id.

In concluding that the broadest form of relief consistent with the Act’s remedial purposes is necessary and appropriate in this case, I have placed particular emphasis on the Union’s demonstrated conduct and attitude as manifested through its response to the Third Circuit’s Consent Order and its continued assignment of Della Vella to a position of responsibility for picketing activities.  In my view, the situation is similar to that presented in Iron Workers Local 378 (N.E. Carlson Construction), 302 NLRB 200 (1991).  In Carlson, a case involving picketing conduct found to be unlawful under Section 8(b)(4)(i) and (ii)(B) of the Act, the Board modified the judge’s order by substituting broad cease-and-desist language.  It noted that the case involved the second adjudicated episode of such misconduct.  Beyond this, it took special cognizance that the business agent who directed the misconduct in both cases was the same individual, one Trujillo.  In delineating its reasons for imposing a broad order, the Board held that (302 NLRB at 201):

 

We further find that the Respondent’s violations in this case, considered against the background of similar events in [the prior case] and giving particular emphasis to the behavior of the Respondent’s business agent Trujillo, are so egregious as to manifest a general disregard for the rights of neutral employees and employers.  This unlawful conduct convinces us that, without proper restraint, the Respondent is likely to engage in similar conduct in the future against employers other than those involved here.  Accordingly, a broad remedial order is appropriate.  [Footnote omitted.]

 

In my view, it is equally likely that Local 98 and its agent, Della Vella, may engage in various types of misconduct against employees of this employer and other employers in violation of Section 8(b)(1)(A) of the Act and in contravention of the Section 7 rights of employees of this employer and other employers. 

Finally, in reaching this conclusion, I have weighed the limited nature of the violation in this case and the evidence showing that the conduct, standing alone, was not violent or otherwise egregious.  While significant, this cannot override the compelling weight of the evidence demonstrating an extensive history of misconduct, an ingrained hostility to the Act’s purposes, and a persistent disregard of the remedial measures previously imposed by the Board and the court of appeals.  It is those considerations which impel me to recommend imposition of the relief requested by the General Counsel.   

On these findings of fact and conclusions of law and on the entire record, I issue the following recommended24.

ORDER

The Respondent, International Brotherhood of Electrical Workers, Local Union No. 98, Philadelphia, Pennsylvania, its officers, agents, and representatives, shall

1. Cease and desist from

(a) Restraining or coercing employees of Tri-M Group, LLC, or any other employer, by blocking them from entering a jobsite or performing a work task.

(b) In any other manner restraining or coercing employees of Tri-M Group, LLC, or any other employer, 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) Within 14 days after service by the Region, post at its union office in Philadelphia, Pennsylvania, copies of the attached notice marked “Appendix.”25 Copies of the notice, on forms provided by the Regional Director for Region 4, 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 members 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.

(b) Sign and return to the Regional Director sufficient copies of the notice for posting by Tri-M Group, LLC, if willing, at all places where notices to employees are customarily posted.

(c) 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.  April 10, 2007

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 restrain or coerce employees of Tri-M Group, LLC, or any other employer, by blocking them from entering a jobsite or performing a work task.

We will not in any other manner, restrain, or coerce employees of Tri-M Group, LLC, or any other employer, in the exercise of the rights guaranteed to them by Federal labor law.

 

International Brotherhood of Electrical Workers, Local Union No. 98



1 The Respondent has excepted to some of the judge’s credibility findings.  The Board’s established policy is not to overrule an administrative law judge’s credibility resolutions unless the clear preponderance of all the relevant evidence convinces us that they are incorrect.  Standard Dry Wall Products, 91 NLRB 544 (1950), enfd. 188 F.2d 362 (3d Cir. 1951).  We have carefully examined the record and find no basis for reversing the findings.

2 In affirming the judge’s granting of a broad cease-and-desist order, we do not rely on his conclusion that conduct occurring 4 or more years prior to the violation at issue cannot be considered in determining whether a party is a recidivist offender of the Act.  Rather, we will assess the totality of the circumstances in each case, including the applicable dates of misconduct and prior Board and court orders, to determine whether a broad order is warranted.  See generally Five Star Mfg., 348 NLRB No. 94 (2006).  Under these circumstances, we find that the record sufficiently establishes that the Respondent has a proclivity to violate the Act, and thus warrants our adoption of the judge’s broad order.

1 All dates are in 2006 unless otherwise indicated.

2 At trial, counsel for the General Counsel moved to amend the complaint to reflect the Charging Party’s correct name and form of organization under Pennsylvania law.  This motion was unopposed, and I granted it.

3 Counsel for the General Counsel has filed a motion to correct the transcript.  His page reference numbers differ from those in the official transcript furnished to the Board by the reporting service.  As a result, I am unable to verify his suggested corrections.  Fortunately, as is apparent from the brevity of his motion, there are