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.

Valerie Manor, Inc. and New England Health Care Employees Union, District 1199, SEIU.  Cases 34–CA–11162, 34–CA–11236, and 34–RC–2116

December 28, 2007

DECISION, ORDER, AND DIRECTION OF
SECOND ELECTION

By Members Liebman, Kirsanow, and Walsh

On June 23, 2006, Administrative Law Judge Howard Edelman issued the attached decision.  The Respondent filed exceptions and a supporting brief.1  The General Counsel filed cross-exceptions and a supporting brief, and an answering brief to the Respondent’s exceptions.  The Respondent filed an answering brief to the General Counsel’s cross-exceptions.

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

The Board has considered the judge’s decision and the record2 in light of the exceptions,3 cross-exceptions,4 and briefs and has decided to affirm the judge’s rulings,  findings,5 and conclusions6 as modified and to adopt the recommended Order as modified and set forth in full below,7 and finds that the election must be set aside and a new election held.8

ORDER

The National Labor Relations Board adopts the recommended Order of the administrative law judge as modified below and orders that the Respondent, Valerie Manor, Inc., Torrington, Connecticut, its officers, agents, successors, and assigns, shall

1.  Cease and desist from

(a) Coercively interrogating any employee about their union sympathies.

(b) Threatening employees with facility closure, layoffs, job loss, loss of benefits, or other unspecified reprisals if they select the New England Health Care Employees Union, District 1199, SEIU, as their representative.

(c) Soliciting employees to revoke their union authorization cards.

(d) Threatening employees that unionization would be futile.

(e) Threatening employees that a strike would be inevitable if they selected the Union as their representative.

(f) Threatening to withhold a wage increase because of union activity.

(g) Promising to grant employee benefits if the employees do not select the Union as their representative.

(h) Using employee signatures on an antiunion petition without their consent.

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

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

(a) Within 14 days after service by the Region, post at its facility in Torrington, Connecticut, copies of the attached notice marked “Appendix.”9  Copies of the notice, on forms provided by the Regional Director for Region 34, 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 February 2005.

(b) 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.

DIRECTION OF SECOND ELECTION

A second election by secret ballot shall be held among the employees in the unit found appropriate, whenever the Regional Director deems appropriate.  The Regional Director shall direct and supervise the election, subject to the Board’s Rules and Regulations.  Eligible to vote are those employed during the payroll period ending immediately before the date of the Notice of Second Election, including employees who did not work during the period because they were ill, on vacation, or temporarily laid off.  Also eligible are employees engaged in an economic strike that began less than 12 months before the date of the election directed herein and who retained their employee status during the eligibility period and their replacements.  Those in the military services may vote if they appear in person at the polls.  Ineligible to vote are employees who have quit or been discharged for cause since the payroll period, striking employees who have been discharged for cause since the strike began and who have not been rehired or reinstated before the date of the election directed herein, and employees engaged in an economic strike that began more than 12 months before the date of the election directed herein and who have been permanently replaced.  Those eligible shall vote whether they desire to be represented for collective bargaining by the New England Health Care Employees Union, District 1199, SEIU.

To ensure that all eligible voters have the opportunity to be informed of the issues in the exercise of their statutory right to vote, all parties to the election should have access to a list of voters and their addresses that may be used to communicate with them.  Excelsior Underwear, 156 NLRB 1236 (1966); NLRB v. Wyman-Gordon Co., 394 U.S. 759 (1969).  Accordingly, it is directed that an eligibility list containing the full names and addresses of all the eligible voters must be filed by the Employer with the Regional Director within 7 days from the date of the Notice of Second Election.  North Macon Health Care Facility, 315 NLRB 359 (1994).  The Regional Director shall make the list available to all parties to the election.  No extension of time to file the list shall be granted by the Regional Director except in extraordinary circumstances.  Failure to comply with this requirement shall be grounds for setting aside the election if proper objections are filed.

Dated, Washington, D.C.   December 28, 2007

 

______________________________________

Wilma B. Liebman,                                   Member

 

______________________________________

Peter N. Kirsanow,                                   Member

 

______________________________________

Dennis P. Walsh,                                     Member

 

(seal)            National Labor Relations Board

APPENDIX

Notice To Employees

Posted by Order of the

National Labor Relations Board

An Agency of the United States Government

 

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

federal law gives you the right to

Form, join, or assist a union

Choose representatives to bargain with us on your behalf

Act together with other employees for your benefit and protection

Choose not to engage in any of these protected activities.

 

We will not coercively question you about your union sympathies.

We will not threaten you with facility closure, lay offs, job loss, loss of benefits, or other unspecified reprisals if you select the New England Health Care Employees Union, District 1199, SEIU, as your representative.

We will not solicit you to revoke your union authorization cards.

We will not threaten you that unionization would be futile.

We will not threaten you that a strike would be inevitable if you select the Union as your representative.

We will not threaten to withhold a wage increase because of union activity.

We will not promise to grant employee benefits if you do not select the Union as your representative.

We will not use employee signatures on an antiunion petition without their consent.

We will not in any other manner interfere with, restrain, or coerce you in the exercise of the rights set forth above.

 

Valerie Manor, Inc.

 

Jennifer F. Dease, Esq., for the General Counsel.

Hugh F. Murray III, Esq. and Michael C. Harrington, Esq., for the Respondent.

Kevin A. Creane, Esq., for the Charging Party.

DECISION

Statement of the Case

Howard Edelman, Administrative Law Judge.  These cases were tried in Hartford, Connecticut, on November 7−10, 2005.  On August 31, 2005, a complaint and notice of hearing issued in Case 34–CA–11162, based upon a charge filed by the New England Health Care Employees Union, District 1199, SEIU (Union), alleging that Valerie Manor, Inc. (Respondent), had committed over 60 violations of Section 8(a)(1), including repeated threats of facility closure, job loss, loss of wages and benefits, futility and the inevitability of strikes.  In addition to the charge, the Union also filed numerous postelection objections to the conduct of the NLRB election held on April 14, 2005.  As the objections raised substantial and material issues of fact, and since all but two raised issues identical or similar to the unfair labor practices contained in the complaint, the objections were consolidated with complaint of September 14, 2005.  Based upon an additional charge filed by the Union in Case 34–CA–11236, a second complaint and notice of hearing issued on September 29, 2005, alleging that Respondent had committed further violations of Section 8(a)(1) of the Act.  On September 29, 2005, an Order Further Consolidating Cases issued consolidating the two complaints and objections in Cases 34–CA–11162, 34–CA–11236, and 34–RC–2116.

Respondent filed timely answers to the two complaints.  In its answers, Respondent admitted the commerce allegations, the Union’s labor organization status, the supervisory and/or agency status of all the below-named individuals.  It is also admitted that it presented certain power point presentations, meetings wherein slides were shown to employees, and that it distributed various literature alleged to violate Section 8(a)(1) of the Act.  Respondent generally denied the commission of any unfair labor practices.

Findings of Fact

i.  jurisdiction

At all material times, Respondent, a corporation with an office and place of business in Torrington, Connecticut (the facility), has been engaged in the operation of a nursing care facility.  During the 12-month period ending July 31, 2005, Respondent, in conducting its operations described above, derived gross revenues in excess of $250,000.  During the 12-month period ending July 31, 2005, Respondent, in conducting its operations described above, purchased and received at its facility goods valued in excess of $50,000 directly from points outside the State of Connecticut.

At all material times, Respondent has been an employer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act and has been a health care institution within the meaning of Section 2(14) of the Act.

At all material times, the Union has been a labor organization within the meaning of Section 2(5) of the Act.

At all material times, the following individuals held the positions set forth opposite their respective names and have been supervisors of Respondent within the meaning of Section 2(11) of the Act and agents of Respondent within the meaning of Section 2(13) of the Act:

 

Joseph Colaci

Acting Administrator

Denise Quarles

Administrator

Maureen Markure

Assistant Director of Nurses

Lillian Ciesco

Director of Admissions

Linda Orlowski

Director of Social Services

Darryl Davis

Director of Resident Support Services

Davis Stefanitis

Chef Manager

Nancy Berube

MDS Coordinator, Head Nurse

Susan Maches

Registered Nurse

Bonny Hendrick

Registered Nurse

Tami Chevrier

Charge Nurse

Bill Thomas

Financial Director of Nursing Home Operations, Athena Healthcare

Dee Rosetti

Employee Relations Advocate, Athena Healthcare

Doreen Christiano

Admissions Coordinator, Brookview Health Care Facility

Melissa Moran

Social Worker

 

Respondent’s facility is managed by Athena Healthcare which manages a number of healthcare facilities including Brookview Nursing Home, also located in Torrington, Connecticut.

ii.  credibility

I credit all of the General Counsel’s witnesses.

I was impressed with the General Counsel’s witnesses’ overall demeanor.  These witnesses were most responsive and forthright during both direct and cross-examination.  Moreover, they made admissions against their interest when their cross-examination conflicted with their pretrial affidavits.  These differences were restricted to the words “would” or “could,” which I have found in this case that such differences were immaterial and reflected threats.

Further their testimony, especially during meetings was essentially corroborated by other employees.  For example, a number of employees testified that during the first meetings conducted by Joseph Colaci as to different large sums of money he was willing to spend to keep the Union out.  I find that the variance of the different sums of money reflect truthfulness because over a period of months employees are likely to remember different figures.  However, the thrust of all of their testimony was that Colaci would spend any sum of money to keep the Union out.

Moreover, all of the General Counsel’s witnesses were employed by Respondent during the course of the trial.  In Conair Corp., 261 NLRB 1189, 1266 (1982), the judge set forth:

 

As employees of Respondent their testimony was given at considerable risk . . . and is not likely to be false.

The judge’s credibility findings were upheld by the Board.

 

If there were any inadvertent specific failures on my part to make a credibility resolution, such credibility resolutions were implicitly set forth in my resolution and analysis of all of the complaint violations.   Amber Foods, Inc., 338 NLRB 712, 713 fn. 7 (2002).

iii.  credibility of respondent’s witnesses

I found Respondent’s witnesses not credible.

Respondent witnesses, especially Joe Colaci and Bill Thomas testified in generalities.

The supervisor presenters of the slide shows had virtually no recollection of their statements to employees between the slides, as contrasted with the specific testimony of employees.  Moreover, virtually no Respondent witness contradicted the General Counsel’s witnesses, especially in the slide show with testimony, with the exception of broad-leading questions which I have totally rejected as relevant evidence.  Such leading questions by Respondent’s attorneys often they were unable to remember any conversations with employees were, “Did you threaten anyone . . . did you interrogate anyone?,” etc., to which Respondent’s witnesses answered no.

Further, a number of Respondent’s witnesses did not appear at the trial to give relevant and corroborative testimony.  No explanation was given by Respondent why they did not appear.

Detailed discussions as to the credibility of the witnesses are set forth below:

Facts of the Case

Rena Bailey is employed as a certified nurse’s assistant, CNA.  She works the 3 to 11 p.m. shift.  She works at the Skyview and Meadowview sections of Valerie Manor.

Some time in late February after the Union began organizing Respondent, Bailey signed a union card.  Shortly after signing this card she attended a meeting with Joseph Colaci and Lillian Ciesco in the Pineview dining room.  Bailey and three other employees were present.

Colaci stated that he heard that we signed union cards and he wished that we would ask the Union for our cards back.  He stated that he didn’t blame us for signing them.  He then said he didn’t want a union at Valerie and that he would spend a million dollars to fight it.

I find Colaci’s solicitation to ask employees for union signed cards is a violation of Section 8(a)(1) of the Act.  Mohawk Industries, 334 NLRB 1170, 1171 (2001), which states that as a general rule, an employer may not solicit employees to revoke their union cards . . . in an atmosphere where employees would tend to feel peril in revoking union cards.  Such atmosphere was created by Colaci’s statements, set forth above and below, to the effect that he would spend as much money and do whatever was necessary to keep the Union out.  I also find this threat and similar threats described below to be violative of Section 8(a)(1).  See Gravure Packaging, 321 NLRB 1296, 1299 (1996), enfd. mem. sub nom. 116 F.3d 941 (D.C. Cir. 1997), where the employer stated that he would do everything in his power to keep the union out, also Soltech, Inc., 306 NLRB 269, 272 (l992), where the Employer stated that the company would do everything it could to assure the company would be nonunion.

Bailey also testified that Ciesco said that in Adams House, managed by Athena, located in a neighboring town, was down 20 beds because of the Union.  She stated that she is an admission coordinator and the first thing a loved one asks her is whether the facility is a union facility because they don’t want to put their loved one in a union home because they felt that they wouldn’t get proper care.  The General Counsel contends that this is an implied threat of loss of jobs.

The General Counsel also contends that Ciesco threatened employees with a loss of customers if they selected the Union when she informed them that the first thing potential customers ask is whether the facility is unionized and that customers told her that they would not put their loved ones in a union home.  Ciesco’s statements thereafter linked unionization with the loss of beds at Adams House, and that union facilities are unstable and are always changing hands.  The General Counsel contends that such statements imply that the employees at Respondent’s facility would experience the same fate.  The General Counsel thereafter contends Respondent failed to show that this threat of customer loss had an objective basis indicating probable consequences of Respondent’s control.  I find no violation in view of Stanadyne Automotive Group, 345 NLRB 85, 89 (2005).

The Supreme Court described the balance between employer free speech rights as codified by Section 8(c) and employees’ Section 7 rights in NLRB v. Gissel Packing Co., 395 U.S. 575, 618 (1969).

 

[A]n employer is free to communicate to his employees any of his general views about unionism or any of his specific views about a particular union, so long as the communications do not contain a ‘threat of reprisal or force or promise of benefit.’  He may even make a prediction as to the precise effects he believes unionization will have on his company.

 

In Stanadyne, Binkus, an employee and agent, explained that a striker at another Stanadyne plant resulted in the death of a guard who was struck in the head during an altercation with the union employees, stating:

 

The action we take as individuals does, at times, result in something completely unplanned.  Let’s not let any unplanned action take place here.  Violence, threats, intimidation, and a death are not things that happen just on TV or something you read somewhere about another company.  They happened at UAW locations at former Stanadyne facilities.

 

The Board held that:

 

To the extent that the Respondent’s message may be construed as a ‘predication’ of the effects of unionization, in spite of its assurances to the contrary, we find that its statements were ‘carefully phrased on the basis of the objective fact to convey [the Respondent’s] belief as to demonstrably probable consequences beyond [its] control.’

 

In TNT Logistics North America, 345 NLRB 290 (2005), the Board stated:

 

With regard to the supervisor’s statement that ‘if the Union comes in we wouldn’t have a job with Home Depot,’ we note initially that Haynes told Cook that Home Depot does not do business with unionized carriers.  No party disputes the accuracy of Haynes’ comment that Home Depot was not union friendly and did not have any union carriers, or the testimony that the Employer’s contract with Home Depot was due to expire in October 2005.  Inasmuch as these statements are uncontroverted, we view them as objective fact.  Based on these circumstances, Haynes predicted that Home Depot would cease doing business with the employer if the Employer’s employees selected the Union.  Home Depot’s possible actions were beyond the Employer’s control.  Furthermore, Haynes made no threats, nor were his comments interspersed with comments against the Union.  We find that, in this context, Haynes’ statement would reasonably be understood as nothing more than an expression of personal opinion as to what Home Depot, a client of the Employer, might do in the event of the Employer’s unionization.  Making this possibility known to employees does not constitute objectionable conduct.  Accordingly, in these circumstances, we find that Haynes’ statement conveyed his personal ‘belief as to demonstrably probable consequences beyond [the Employer’s] control,’ based on objective fact, which is permissible under Gissel.

 

Counsel for the General Counsel contends that in Stanadyne the Board stated:

 

Further, the speakers [of Stanadyne] repeatedly made clear that they were not making threats or predictions about the future, but rather, presenting ‘facts and recollections about actual events.’  By providing ‘concrete examples[s] of a negative outcome for employees who were represented by the same union that seeks to represent’ the Respondent’s employees, the Respondent ‘made no prediction at all.’  Manhattan Crowne Plaza [Town Park Hotel], 341 NLRB 619, 620 (2004).

 

However this paragraph was merely a further, or moreover position, and not essential to the Board’s decision.

Accordingly, I find Ciesco’s statements are based upon objective considerations, and upon a reasonable prediction.

Bailey also testified that Ciesco stated that if we did become union, the Union would be forced to strike.  Ciesco did not testify as to this conversation.  I credit Bailey’s testimony.

I conclude Ciesco’s statement constitutes a threat to strike and loss of jobs in violation of Section 8(a)(1).  See Heartland of Lansing Nursing Home, 307 NLRB 152, 158 (1992).

A day or so following Colaci’s appointment as administrator of Respondent, Colaci testified he met with the employees in the Pineview of Valerie Manor.  He had a number of meetings in the Pineview so that all the employees could appreciate his position.  Colaci testified he told the employees at each meeting pretty much the same thing.  Colaci told the employees that it was his belief that unions did not belong in health care, and that we would work hard to keep Valerie Manor nonunion.  During these meetings I would tell the employees that I was willing to spend $100,000 to keep Valerie nonunion.  Colaci testified that during these meetings, employees asked questions about revoking their union authorization cards.  And Colaci responded that they could go to the Union and ask for their card back.

I find by Colaci’s statement to the effect that he would do whatever he had to do to keep the Union out, coupled with his asking his employees to get their union cards back, again unlawfully solicited his employees at this meeting to get their signed union cards back in violation of Section 8(a)(1).  See Mohawk Industries, supra.

Colaci’s statement that he would do anything necessary to keep the union out is also an implied threat of unspecified reprisals.  See Gravure Packaging and Soltech Inc., supra.

Colaci also told the employees that other nursing homes closed because of unions.  I do not find this to be a violation.  See Stanadyne, supra.

On or about February 28, Kathy Carey, Tammy Robison, Dianne Sullivan, and Carolyn Clark attended a meeting conducted by Colaci in the Pineview dining room.  About 15 employees attended the meeting.

Cary testified that Colaci stated that he heard that we were trying to bring in a union and that if we would stop, they could talk to us about giving raises.  Colaci does not deny this statement.  I credit Cary’s testimony.

I find this statement to be an unlawful promise of benefits, in violation of Section 8(a)(1).  K-Mart Corp., 336 NLRB 455, 472 (2001).

Cary also testified that Colaci stated that Respondent would spend whatever it would take to stop the Union.  Clark testified that Colaci told the employees that he would spend $100,000 to keep Respondent nonunion.  Colaci did not deny this statement.  I credit Cary’s testimony.

I find these statements to constitute a threat of futility and violative of Section 8(a)(1).  Gravure Packaging and Soltech, supra.

Diane Sullivan, a CNA, testified that Colaci said that he didn’t blame us for calling the Union, but he would like us to revoke our cards that we had signed for the Union. He then stated that he didn’t want Valerie Manor to become a union facility, and asked us to give the administrator a chance.  He said that he couldn’t talk about money until this business with the Union was over.  Colaci did not deny this statement.  I find Colaci tied his request for employees to revoke union cards with the statements above.  Under these circumstances, I find that Colaci’s statement to Sullivan about revoking her union card is a violation of Section 8(a)(1).  Mohawk Industries, supra.

I also find Colaci’s statement that he didn’t want Respondent to be union coupled with the statement that he couldn’t talk about money constitutes a promise of benefits and is a violation of Section 8(a)(1).  See K-Mart Corp., supra.

Tammy Robison, a CNA, testified that Colaci stated that he didn’t blame us for calling the Union.  He then asked us to give him a chance and to revoke our signed union cards.  He also said he couldn’t talk about money until after the union.  Colaci did not deny this statement.

I find Colaci’s statement about revoking signed union cards is a violation of Section 8(a)(1).  Mohawk Industries, supra.  I also find his statement that “he couldn’t talk about money until after the Union,” coupled with his statement about revoking the signed union cards is an implied promise of raises once the Union is out of the picture and is violative of Section 8(a)(1).  See K-Mart Corp., supra.

Lillian Ciesco, director of admissions, also spoke to a group of employees.  Robison testified that Ciesco stated that family members who were considering placing their loved ones at Adams House were asking whether the facility was Union before they would make a decision concerning putting their loved ones.  Ciesco also said Adams House had 20 empty beds.

The General Counsel contends that Ciesco’s statement clearly implies that what happened to Adams House, which was Union, would happen to Respondent if the Union was elected.  The loss of beds would equate to the loss of employees I find Ciesco’s statements constitute lawful predictions.  See Stanadyne, supra.

As set forth above, Colaci had similar meetings with different groups of employees concerning the advent of the Union, during the last week in February.  Michelle Hudson, a CNA testified that Colaci met with Hudson and about 12 employees in the Pineview dinning room.  She testified that Colaci told the employees he knew the employees were signing cards for the Union and that he didn’t want a union in his building.  He stated that he would pay hundreds of thousands of dollars not to have them in his building.  He then told the employees that if they had signed union cards they could give them back to the Union and he wouldn’t hold it against them.

I find Colaci’s statement about his knowledge of employees signing union cards and that he didn’t want a union in Respondent’s facility, his statement to pay hundreds of thousands of dollars to keep the Union out constitutes an unlawful solicitation that the employees should not sign union authorization cards or to revoke signed cards, and is a violation of Section 8(a)(1).  See Mohawk Industries, supra.  I also find Colaci’s statement that he knew about employees signing union cards is surveillance in violation of Section 8(a)(1).

I also find that Colaci’s statement about paying hundreds of thousands of dollars to keep the Union out constitutes an unlawful threat of futility.  See Gravure Packaging and Soltech, Inc., supra.

Employees Joan Champagne, Marsha Deming, and Danielle Robison, kitchen employees, met with Colaci, Joe DeVito, administrator at Athena, and Theresa Meyers, supervisor, sometime in late February.  Champagne testified that either Colaci or DeVito said they didn’t want the Union and that another facility owned by Athena had closed because of the Union, and they were going to fight it.  They said this fight was going to cost a lot of money and that there wouldn’t be any money for raises.  I credit Champagne’s testimony.  Her testimony is corroborative with all of the General Counsel’s witnesses above.

I find no violation in connection with Colaci’s or DeVito’s statement concerning another facility had closed because of the Union.  See Stanadyne, supra.  However, I do find that the statement that “this fight,” a reference to the union campaign, was going to cost a lot of money and there wouldn’t be any money for raises, constitutes a threat to reduce employee benefits in violations of Section 8(a)(1).  Pembrook Management, 296 NLRB 1226, 1239 (1989), and Heartland Lansing Nursing Home, 307 NLRB 152, 158 (1992).

Marsha Deming, an aide, testified that Colaci told employees that he didn’t want a union in the place and that he would spend $100,000 and that the place would close.  He also stated he would take out a second mortgage on his home to keep the Union out.  Again, such testimony is essentially corroborative with the General Counsel’s witnesses described above.

I find Colaci’s statement to be a threat to close the facility and an implied threat of unspecified reprisals.  Gravure Packaging and Soltech, Inc., supra.

With regards to the threat of closure of the facility, Respondent’s statements regarding plant closing that might result from unionization are also evaluated within the “total context” in which they appear, under standards established by the Supreme Court’s Gissel decision.  Such statements have sometimes, but rather seldom, been found to be predictions “based on objective fact.”  Far more commonly, the Board has deemed them coercive threats.  In Atlas Microfilming, 267 NLRB 682 (1983), for example, the Board found a violation where a supervisor told all the employees in her department that the plant would close if the employees selected the union.  See also Highland Yarn Mills, 313 NLRB 193, 206, 209 (1993).

Robison testified that Colaci stated he heard a union was coming in and he didn’t want it in there.  He said he had stock in Valerie and if Valerie Manor were to go union his stock would be no good.  It would be devalued.  He said he would fight to the end and would pay $80,000 to $100,000 to prevent the Union from coming in and that the Union would have to start from ground zero.  Again, her testimony is corroborated by the witnesses described above.

I find this statement a threat of futility in violation of Section 8(a)(1).

Deming and Robison also testified that Colaci stated he would spend $100,000 and if necessary he would take out a second mortgage and he would fight to the end.  I find these statements express a futility of supporting the Union and in violation of Section 8(a)(1).  See Gravure Packaging and Soltech Inc, supra.  Moreover, Colaci’s statement that the Union would have to start bargaining from ground zero, also violates Section 8(a)(1) given the multitude of Section 8(a)(1) violations in this case.  See Superior Emerald Park Landfill, LLC, 340 NLRB 449, 461 (2003).  I find this statement a threat of futility in violation of Section 8(a)(1).  Gravure Packaging and Soltech, Inc., supra.

Joan Champagne, a CNA, testified that either Colaci or DeVito stated that another facility owned by Athena had closed because of the Union.  I find such statement does not violate the Act.  See Stanadyne, supra.

Darla Jacobs, a CNA, testified that Supervisor Darryl Davis told her that Colaci wanted to meet with her.  Jacobs had missed the general meetings discussed above.  During this meeting Jacobs testified that Colaci said he knew the employees were upset; he knew that union cards were being passed out, and said the Union wasn’t the answer.  Colaci then stated that he would spend 80 to $100,000 to keep the Union out, he was a shareholder, and had a mortgage, and had bills to pay himself.  There was no money, that’s all they had.

I find Colaci’s statement that he would spend up to $100,000 to keep the Union out, that he had a mortgage and bills to pay and there was no money, that’s all they had, to be violative of Section 8(a)(1), an unlawful statement of futility.  See Gravure Packaging and Soltech, Inc., supra.

During the meetings described above neither Colaci, Ciesco, or DeVito denied any of the statements described above.

Darla Jacobs testified that she had a conversation with Bonnie Hendricks, a registered nurse, and an admitted supervisor within the meaning of 2(11) of the Act, on or about February 26.  During this conversation Hendricks told Jacobs “What do you think about the Union stuff going on?” Jacobs testified that she was an adult, that she would hear both sides and that she would make a decision.  Hendricks then stated Athena would close the place if the Union came in.  She then told Jacobs that when she was younger she worked for a place and the union came in and they closed it.  She did not state why it was closed or the name of the facility.

Respondent did not call Hendricks as a witness.

However, I find Hendrick’s statement that “Athena would close the place if the Union came in” is a clear threat to close the shop and a violation of Section 8(a)(1).  See Gissel Packaging, supra, and Highland Yarn Mills, 313 NLRB 193, 206, 207 (1993).  I do not find her testimony concerning closing a facility where she once worked to be a violation.  See Stanadyne, supra.

Additionally, I find Hendrick’s statement “What do you think about the Union stuff going on?” to be an unlawful interrogation.  As the General Counsel points out in her brief, such interrogation was accompanied by an unlawful threat.  Accordingly, I find such interrogation a violation of Section 8(a)(1).  See Hoffman Fuel Co., 309 NLRB 327 (1992); Rossmore House, 269 NLRB 1176 (1984), affirmed 760 F.2d 1006 (9th Cir. 1985).

Diana DuPont, a CNA, was employed by Respondent for 3 years working the night shift.  DuPont testified she had a discussion with Nancy Berube, an admitted supervisor, in the Skyview section of Valerie Manor.  CNA’s Ellen Dalene and Irene Pisarcyk were present.  DuPont testified that Berube asked them what they thought about the Union.  DuPont recalls there was some conversation that took place, and then Berube said “if Valerie Manor became unionized, that Athena would sell it.”  I credit DuPont’s testimony.  I find such statement to be a threat to close Respondent’s facility if the Union came in.  Gissel Packaging and Highland Yarn Mills, supra.

Berube admitted that she had a conversation with Dalene, Pisarcyk, and DuPont sometime between late February and March 7.  Berube testified that she told them about an instance where she worked in another building and it became unionized and eventually it closed down.  She did not name the facility.  I find no violation in this connection.  See Stanadyne, supra.

Tammy Robison testified that after their general meeting with Colaci, she and Dianne Sullivan and Carolyn Clarke met with Supervisor Tammy Chevrier.  Robison testified that Chevrier stated Valerie Manor would never accept the Union and if the Union came in they would sell or close the facility and we could lose our jobs.  Sullivan and Clarke corroborated Robison’s testimony.  Chevrier could not recall this conversation.

I find Chevrier’s statement is a direct threat to close Respondent’s facility if the Union came in, and a violation of Section 8(a)(1).  See Gissel Packaging and Highland Yarn Mills, supra.

Deming testified that the employees would take their breaks in an area in back of the facility.  There is a back doorway and two small picnic tables where the employees could congregate and smoke.  Deming testified that before the Union filed its petition on March 7, the employees would sit around the two picnic tables during their break times.  Deming testified that Darryl Davis and David Steponitis, low-level supervisors, would usually hang around the doorway area.  Deming testified that every time she took a break it seemed both supervisors were present and sitting or standing around the picnic tables.

Deming admitted that Davis and Steponitis are smokers, that the area in the back parking lot where the picnic tables are located is the only area where smoking is permitted, and that Davis and Steponitis would smoke at the tables or by the doorway.  Neither Davis or Steponitis spoke to any of the employees during these breaks.

Steponitis admitted that he smoked either at the back door or at the picnic tables and that this practice was the same before the union campaign and after.

I conclude there is insufficient evidence to establish unlawful surveillance.

Post Petition

On March 7, the Union filed a petition for an election.

At some point in time after the Union began to organize the employees, Respondent hired a labor relations consulting firm.  This firm drew up well over 170 slides with short messages as to why it was better for its employees to remain nonunion, the aspects of the collective-bargaining process including strikes, and the repercussions that must be considered.  These slide shows were divided into three presentations called “Power Points.”  Each presentation lasted 1 week.  The first presentation was called “questions and answers,” the second presentation was called “collective bargaining” the third presentation was called “Facts.”  The slide shows lasted about an hour or so.  These slide shows were conducted by 2, 3, or 4 supervisory employees who met with small groups of employees, 4 to 15 employees.  The slides were projected on a large screen, easily readable.  The presenters read the slides, and between the slides there would be discussions between the presenters and the employees; questions and answers.  The meetings were mandatory.  The employees would sign in.  The meetings were held round the clock each week, during working hours.  The employees were paid for the time spent during the meeting.

Unlawful 8(a)(1) Statements Made by Supervisors
Between Slide Show

Respondent held a power point presentation on March 22, 2005, at 1:30 p.m.  The presenters were Linda Orlowski and Theresa (Tree) Meyers.  It should be noted that Orlowski conducted a number of slide show meetings.  Pursuant to Respondents direct examination Orlowski could not recall any of the conversations with employees at any of the meetings she conducted.  Through Respondent’s attorney’s leading questions, Orlowski simply testified “no” as to Respondent’s witnesses’ testimony relating to alleged 8(a)(1) conduct.  For example, Respondent’s counsel would ask a leading question like “Did you ever threaten any employees?”  The answer was always “No,” etc.

Meyers did not testify.

Dianne Sullivan credibly testified that Orlowski stated “If we went out on an economic strike we won’t receive pay, unemployment benefits and our health coverage would end.”  Sullivan further testified that Orlowski also stated “The Union doesn’t care about families or residents, and that we would lose everything.”  I find such statement to be a threat to lose benefits and wages and a clear violation of Section 8(a)(1).  See Pembrook Management, 296 NLRB 1226, 1239 (1989).  In Pembrook, the Judge found a statement “If the Union got in all present benefits might be lost” to be violative of Section 8(a)(1).

Sullivan also testified that Orlowski stated, “We are a family at Valerie (Respondent).  Give us six months to improve.”  I find that such statement especially coupled with the above threat of “losing everything” is an implied promise of improved benefits.  See Hubbard Regional Hospital, 232 NLRB 858, 870 (1977), enfd. in pertinent part 579 F.2d 1251 (1st Cir. 1978).

Sullivan further testified Orlowski stated “With a Union we won’t be able to bend the rules.”

The General Counsel contends the “bend the rules” statement is violative of Section 8(a)(1).  I do not find such statement to be a violation of Section 8(a)(1).  See Pembrook Management, supra at 1227, where the Board cited Tri-Cast, Inc., 274 NLRB 377 (1985), involving exactly the same conduct, and concluded such conduct “is nothing more or less then permissible conduct.”

Jacobs testified that a slide show was conducted on March 23 at 10 a.m. and 11 employees attended.  Lillian Ciesco and Melissa Moran took turns reading the slides which were projected on a screen.  Ciesco and Moran made comments between reading the slides.  Jacobs testified that Moran said we can check the financial records with Colaci, that Respondent has no money, and that Ciesco and Moran said that if there was a strike we “could” lose our jobs.

Moran did not testify and although Ciesco testified, she could not recall any conversation employees raised concerning the Union or Jacobs’ testimony as set forth and described above.  Pursuant to Respondent’s attorney’s usual leading questions, Ciesco denied any unlawful activity, i.e., did you promise raises, “No,” threaten discharges, etc., “No.”

I find the statements by Ciesco and Moran establish a threat of the inevitability of a strike which would cause the employees to lose their jobs.  Heartland of Lansing Nursing Home, 307 NLRB 152, 158 (1992).

In connection with the phrase “if there was a strike we ‘could’ lose our jobs.” it is well settled that a prediction of plant closure as a possibility rather than a certainty is violative of the Act.  Daikichi Corp., 335 NLRB 622, 624 (2001); McDonald Land & Mining Co., 301 NLRB 463, 466 (1991).  Indeed in Gissel, 395 U.S. 575, 616–620 (1969) itself, where the standards for evaluating the lawfulness of predictions of adverse consequences based on the Union’s appearance were formulated, that if the employer stated that a strike, “could lead to the closing of the plant,” violated Section 8(a)(1) as a threat to strike.  Id. at 588.  Indeed past decisions have recognized as threats statements using “could” and statements using “would.”  Compare, e.g., Thayer Dairy Co., 233 NLRB 1383, 1388 (1977).  “Our sincere belief is that if this Union were to get in here, it . . . could work to your serious harm.” was a threat.  W. E. Carlson Corp., 346 NLRB 431 (2006).

Moreover, in the instant case the alleged threat that “if there was a strike we could lose our jobs.” was not followed by the Laidlaw reinstatement rights.1

On March 23, a meeting was conducted at 1:30 p.m.  Orlowski and Jodie O’Brien conducted this meeting.  Seven employees attended this meeting.

Tammy Robison testified that Orlowski stated that we would have to pay union dues, and they could change the assessment of dues whenever they wanted to; that negotiations with the Union could take 2 years and the parties could reach an impasse, and if it went to impasse you could be forced to strike; you could lose your job, and your house.

Kathy Carey testified that Orlowski said they wouldn’t be able to help us with our jobs if we had a Union, that we would have to have to start paying dues after the election, that we would be forced to strike if the Union were elected, and that we would lose our vacations and seniority.

Orlowski admitted that she conducted the above meeting with O’Brien but had no recollection as to what she, O’Brien or any of the employees attending the meeting said.  Orlowski was unable to recall any questions put to her or responses she might have made to employees.  Pursuant to the usual leading questions, she denied any unlawful conduct.  O’Brien did not testify.

Robinson and Carey credibly testified that Orlowski stated negotiations with the Union could take 2 years and the parties could reach an impasse.  I find this statement to be a threat of futility.  See Airtex, 308 NLRB 1135 (1992).  See also Daikichi Corp., supra, as to “could” or “would.”

They also testified Orlowski’s statement about impasse which I found unlawful coupled with the statement that you could be forced to strike, lose your job and your house constitutes a clear threat that the employees would have to inevitably strike and lose benefits and their home.  See Gissel Packaging and Heartland of Lansing Nursing Home, supra.

Hudson testified that Orlowski threatened Hudson and the other employees that “they would have to start from the beginning.”  I find such statement given the multitude of unfair labor practices to be a threat of futility, in violation of Section 8(a)(1).  See Superior Emerald Park Landfill, LLC, 340 NLRB 449, 460, 461 (2003).

On March 24 at 10 a.m., another slide show was conducted by Orlowski and Ciesco. Eleven employees were present.  Mary Roberts, a CNA, credibly testified that following the slide show Orlowski stated that “If you vote in favor of the Union on Thursday a Union could2 take us out on strike on Friday.”  I find this a clear threat of the inevitability of strike.  See Heartland of Lansing Nursing Home, supra.  Orlowski also stated that if you went on strike the facility could be sold or closed.  I find this statement is an unlawful threat to close the facility in violation of Section 8(a)(1).  See Gissel Packaging and Atlas Microfilming, supra.  Orlowski also stated you could lose your benefits or seniority.  This threat is virtually the same threat that was made to Roberts and Carey described above on March 23.  Accordingly, I find this statement to be a threat of loss of benefits in violation of Section 8(a)(1).  See Heartland of Lansing Nursing Home, supra; Pembrook Management, 296 NLRB 1226, 1239 (1989), and Daikichi Corp., supra.

Hudson also testified that Orlowski said that if the Union comes in we would lose our benefits, seniority, our vacation time, and we would have to start from the beginning.  I find this statement to be a threat of loss of benefits in violation of Section 8(a)(1), a threat of futility as to bargaining with the Union.  See Pembrook Management and Heartland of Lansing Nursing Home, supra, and as to the threat of futility, a violation of Section 8(a)(1).  See Gravure Packaging, supra.

Employee Marsha Deming testified that Ciesco stated that outside individuals considering placing their loved ones in Valerie Manor would call the Manor and ask if the facility was Union and that they did not want to place their loved one in a union home.  I find insufficient facts to establish a violation.

Ciesco also threatened employees that union homes went out of business because they were unionized.  Ciesco cited Adams House as an example.  In this connection she stated that 20 beds were down at Adams House.

I find such statements not to be violative of the Act.  See Stanadyne, supra.

On March 24 at 11:30 a.m., a meeting was conducted by Nancy Berube and Tree Meyers, three employees were present at this meeting.  Diana DuPont testified that at some point during this slide show Berube stated that if Valerie Manor became unionized the employer would have to sell.

Berube was not questioned by Respondent’s counsel concerning this meeting.  Meyers did not testify.

I find this a clear coercive threat to close Respondent’s facility.  See Gissel Packaging and Atlas Microfilming, 267 NLRB 682, 687 (1983).

March 28–April 2 Meetings

During this period Respondent presented its second slide show entitled “collective bargaining.”

On March 29 at 10 a.m., Respondent conducted its slide show.  The meeting was conducted by Linda Orlowski and Andy Sebastian, director of maintenance.  Slides would be read and in between slides or groups of slides Orlowski and Sebastian would answer questions and engage in conversations with the employees between slides.

In connection with slides relating to collective bargaining Jacobs testified that during this meeting Sebastian stated that if we go to negotiations we could lose less than we already went in with.  Orlowski stated that we could lose the benefits that we already have if the Union came in.  These benefits included vacations, sick leave, holidays, pension plans, medical insurance, and life insurance.  Jacobs testified that Orlowski without reading from the slides stated we could lose all these benefits if the Union came in.

Orlowski testified she was unable to recall questions put to her by employees or any responses she might have made to employees at any of the slide shows she presented.  Pursuant to the usual leading questions put to her by Respondent’s attorney she denied that neither she nor Sebastian made any unlawful statements.

I find Orlowski’s statements concerning the loss of benefits if the Union was elected as the employees collective-bargaining representative are violations of Section 8(a)(1).  Pembrook  Management, supra, and Superior Emerald Park Landfill, 340 NLRB 449, 461 (2003).

A meeting was scheduled on March 29, 1:30 p.m., and conducted by Ciesco and O’Brien.  Nine employees were present.  Mary Roberts testified that this meeting was about benefits.  Both Ciesco and O’Brien read the slides and made comments in between slides.  Roberts testified that O’Brien stated that if you voted for the Union you would lose all your benefits, for example insurance and health care, and have to start fresh.

Ciesco testified that she did not recall conducting the meetings during the week of March 28 through April 2, and that she did not recall any comments made by her copresenters.  Respondent’s attorney made the usual leading questions and solicited that neither she nor her copresenters stated anything during these meetings that could be considered unlawful conduct.

O’Brien did not testify.  I find O’Brien’s statement constitutes a threat of loss of benefits and a violation of Section 8(a)(1).  See Pembrook Management and Superior Emerald Landfill LLC, supra.

A formal slide show meeting was held on March 31 at 8 p.m.  The meeting was conducted by Orlowski and Meyers.  Three employees attended.  Bailey testified that they had a slide show, and they talked about Unions, particularly a glass company that was Union.  Meyers said we would lose our benefits that we have now with Valerie and Athena if we decided to go Union.

As set forth above, Orlowski was unable to recall questions put to her by employees or any responses she may have made to employees.  Again the same leading questions by Respondent’s attorney denied any unlawful conduct.  Meyers did not testify.

I find Meyer’s statement concerning loss of benefits violates Section 8(a)(1).  See Pembrook Management and Superior Emerald Park Landfill LLC, supra.

Slide Show April 5–9

A formal slide meeting was conducted on April 5 at 10 a.m., by Quarles and Orlowski and eight employees attended.  Jacobs testified that Orlowski stated we were getting wrong information from the Union.  Jacobs also testified Orlowski said 99.9 percent were economic and we could lose our pay, our jobs, and all our benefits.  I find this statement constitutes a threat of loss of benefits.  See Pembrook Management, supra.  I also find the inclusion of jobs in the above threat constitutes a threat of loss of jobs in violation of Section 8(a)(1).  Heartland of Lansing Nursing Home, supra.

Orlowski could not recall any statements that she or Meyers made during this slide show.  Quarles did not testify.  Pursuant to the usual leading questions by Respondent’s attorney Orlowski denied any unlawful conduct.

Carey credibly testified that Sebastian stated that if we joined the Union it would be like joining a sinking ship.  Carey testified that Orlowski said we would go on strike right away and that we would lose our benefits.  I find these statements to constitute a threat to strike and a loss of benefits and a violation of Section 8(a)(1).  See Pembrook Management and Heartland of Lansing Nursing Home, supra.

Carey also testified that Thomas stated if the Union came in, they would not negotiate with the Union.  Thomas did not deny this statement.  I find this statement is a threat of futility.  See Superior Emerald Landfill, supra.

On April 6 at 10 a.m., another slide show was conducted by Bill Thomas, Doreen Christiano, and Quarles.  Twelve employees were present.

Following the slide show Carey testified that Thomas stated that Brookview had laid off 22 employees because they got a Union and that 1199 didn’t care about those employees; he stated that they had to close a unit in Brookview because they had the Union and could not fill the beds.  The General Counsel contends this is an implied threat to close Respondent’s facility if the Union wins the election.  I find such statement is not a threat.  See Stanadyne, supra.

On April 6, a slide show meeting was held conducted by Thomas Christiano and Quarles.

Carey testified that Thomas told the employees at the meeting that Brookview, a nursing home managed by Athena, laid off 22 workers because they, Brookview, were represented by the Union.  Thomas also stated that Brookview had to close a wing because of the Union and they couldn’t fill their beds with residents because it was a union facility.  The General Counsel contends that such statements imply that what took place at Brookview would take place at Respondent’s facility.

For the reasons set forth above, I find no violation.  See Stanadyne, supra.

On April 6, another slide show meeting was held at 11 p.m.  The meeting was conducted by Thomas, Quarles, and Christiano. Thomas told employees at this meeting that Brookview lost 2-1/2 million dollars since it became unionized; that it lost sick days, and vacation days, and that Brookview laid off 22 employees and 68 beds were vacant because people did not want to go to Brookview because it was unionized.  I find that by such statements Respondent was implying that whatever happened at Brookview would happen to Respondent’s employees if they solicited the Union as their representative to be predictions and not loss of benefits.  I find such statements not violative.  See Stanadyne, supra.

DuPont also testified that Thomas told the employees that in the past when Respondent only received 1 percent from Medicare they still gave the employees a 2-percent raise.  Thomas also stated that if Respondent received the 4-percent in funds from the State of Connecticut, it wanted to be able to use that money for the employees, instead of spending it on lawyers and union litigation fees.  Thomas then stated there were a lot of good things that Athena and Respondent were planning for employees, but could not discuss while the labor union was negotiating and that if the labor union won the trial election that Athena and Respon