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.

Pennant Foods Co., a Wholly-Owned Subsidiary of CS Bakery Holdings, Inc., a Wholly-Owned Subsidiary of Chef Solutions Holdings, LLC and International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL–CIO.  Cases 34–CA–11385, 34–CA–11417, 34–CA–11504, and 34–RC–1925

May 12, 2008

DECISION, ORDER, AND DIRECTION OF
THIRD ELECTION

By Chairman Schaumber and Member Liebman

On September 17, 2007, Administrative Law Judge Michael A. Marcionese issued the attached decision.  The Respondent filed exceptions and a supporting brief,[1] the General Counsel filed an answering brief, and the Respondent filed a reply brief.  The Charging Party filed exceptions and a supporting brief, and the Respondent filed an answering brief.

The National Labor Relations 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,[2] and conclusions and to adopt the recommended Order[3] as modified and set forth in full below.[4]

ORDER

The Respondent, Pennant Foods Company, a wholly-owned subsidiary of CS Bakery Holdings, Inc., a wholly-owned subsidiary of Chef Solutions Holdings, LLC, North Haven, Connecticut, its officers, agents, successors, and assigns, shall

1.  Cease and desist from

(a) Coercively interrogating employees about activities on behalf of, or support for, the International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL–CIO (the Union) or any other labor organization.

(b) Threatening employees with the loss of benefits or plant closure if they select the Union or any other labor organization to represent them in collective bargaining.

(c) Denying reinstatement to employees for supporting the Union or any other labor organization.

(d) Creating or discriminatorily applying job descriptions and a light-duty policy in order to prevent employees from returning to work from workers’ compensation leave because of their union membership and activities.

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

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

(a) Within 14 days from the date of this Order, offer Lee Mabry full reinstatement to his former job as a machine operator or to a light duty assignment consistent with any medical restrictions imposed by a physician, or, if his former job no longer exists, to a substantially equivalent position, without prejudice to his seniority or any other rights or privileges previously enjoyed.

(b) Make Lee Mabry whole for any loss of earnings and other benefits resulting from the discriminatory refusal to reinstate him, less any net interim earnings, plus interest in the manner set forth in the remedy section of the judge’s decision.

(c) Rescind the machine operator job description and the worker’s compensation light-duty policy that was utilized to deny Lee Mabry reinstatement in December 2005.

(d) Within 14 days from the date of this Order, remove from its files any reference to the unlawful denial of reinstatement, and within 3 days thereafter notify Lee Mabry in writing that this has been done and that the refusal to reinstate him will not be used against him in any way.

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

(f) Within 14 days after service by the Region, post at its facility in North Haven, Connecticut, copies of the attached notice marked “Appendix”[5] in both English and Spanish.  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 December 21, 2005.

(g) Within 14 days after service by the Region, hold a meeting or meetings, scheduled to ensure the widest possible attendance, at which the attached notice is to be read to the employees by the current plant director, production manager, or corporate vice president for human resources, with translation available for Spanish-speaking employees, and with a Board agent present during the reading.

(h) Within 14 days from the date of this Order, supply the Union the full names and addresses of current unit employees at the North Haven facility, updated every 6 months, for a period of 2 years from the date the notice is posted, or until the National Labor Relations Board has issued an appropriate certification following a free and fair election, whichever comes first.

(i) Provide the Union with notice of, and equal time and facilities to respond to, any address made by the Respondent to employees on the question of union representation, for a period of 2 years from the date the notice is posted, or until the National Labor Relations Board has issued an appropriate certification following a free and fair election, whichever comes first.

(j) Upon reasonable advance notice from the Union, afford the Union and its representatives reasonable access to the Respondent’s bulletin boards and all places where notices to employees are customarily posted at the North Haven facility for a period of 2 years from the date the notice is posted, or until the National Labor Relations Board has issued an appropriate certification following a free and fair election, whichever comes first.

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

It is further ordered that the election in Case 34–RC–1925 shall be set aside and this case is remanded to the Regional Director for Region 34 to conduct a third election at a time and place to be determined by him.

DIRECTION OF THIRD ELECTION

A third 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 Third 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 election date and who retained their employee status during the eligibility period and their replacements.  Jeld-Wen of Everett, Inc., 285 NLRB 118 (1987).  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 election date, and employees engaged in an economic strike that began more than 12 months before the election date and who have been permanently replaced.  Those eligible shall vote whether they desire to be represented for collective bargaining by International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL–CIO.

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 Third 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 whenever proper objections are filed.

Dated, Washington, D.C.   May 12, 2008

 

______________________________________

Peter C. Schaumber,              Chairman

 

______________________________________

Wilma B. Liebman,                                   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 interrogate you about your activities on behalf of, or support for, the International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL–CIO (the Union) or any other labor organization.

We will not threaten you with the loss of benefits or plant closure if you select the Union or any other labor organization to represent you in collective bargaining.

We will not deny you reinstatement for supporting the Union or any other labor organization.

We will not create or discriminatorily apply job descriptions and a light-duty policy in order to prevent you from returning to work from workers’ compensation leave because of your union membership and activities.

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

We will, within 14 days of the date of the Board’s Order, offer Lee Mabry full reinstatement to his former job as a machine operator or to a light-duty assignment consistent with any medical restrictions imposed by a physician, or, if his former job no longer exists, to a substantially equivalent position, without prejudice to his seniority or any other rights or privileges previously enjoyed.

We will make Lee Mabry whole for any loss of earnings and other benefits resulting from our discriminatory refusal to reinstate him, less any net interim earnings, plus interest.

We will rescind the machine operator job description and the worker’s compensation light-duty policy that was utilized to deny Lee Mabry reinstatement in December 2005.

We will, within 14 days from the date of the Board’s Order, remove from our files any reference to our unlawful refusal to reinstate Lee Mabry, and we will, within 3 days thereafter, notify him in writing that this has been done and that the refusal to reinstate will not be used against him in any way.

We will, within 14 days after service by the Region, hold a meeting or meetings, scheduled to ensure the widest possible attendance, at which this notice to employees is to be read to you by our current plant director, production manager, or corporate vice president for human resources, with translation available for Spanish-speaking employees, and with a Board agent present during the reading.

We will, within 14 days from the date of the Board’s Order, supply the Union the full names and addresses of current unit employees at the North Haven facility, updated every 6 months, for a period of 2 years from the date the notice is posted, or until the National Labor Relations Board has issued an appropriate certification following a free and fair election, whichever comes first.

We will provide the Union notice of, and equal time and facilities to respond to, any address we make to you on the question of union representation, for a period of 2 years from the date the notice is posted, or until the National Labor Relations Board has issued an appropriate certification following a free and fair election, whichever comes first.

We will, upon reasonable advance notice from the Union, afford the Union and its representatives reasonable access to our bulletin boards and all places where notices to employees are customarily posted for a period of 2 years from the date the notice is posted, or until the National Labor Relations Board has issued an appropriate certification following a free and fair election, whichever comes first.

 

Pennant Foods Company

 

Jennifer Dease, Esq. and Margaret Lareau, Esq., for the General Counsel.

Gary Glaser, Esq. and Paul Galligan, Esq. (Seyfarth Shaw, LLP), for the Respondent-Employer.

Thomas W. Meiklejohn, Esq. (Livingston, Adler, Pulda Meiklejohn & Kelly), for the Charging Party-Petitioner.

DECISION

Statement of the Case

Michael A. Marcionese, Administrative Law Judge.  I heard this case in Hartford, Connecticut, over 8 days between October 25, 2006, and January 10, 2007. The Charging Party/Petitioner, International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL-CIO (the Union), filed the initial charges in Cases 34–CA–11385 and 34–CA–11417 on January 9 and February 3, 2006, respectively, and amended the charge in Case 34–CA–11417 on March 28 and April 28, 2006. A consolidated complaint based upon these charges issued on April 28, 2006, alleging that the Respondent, Pennant Foods, a wholly-owned subsidiary of CS Bakery Holdings, Inc, a wholly-owned subsidiary of Chef Solutions Holdings, LLC,1 a Questor Company, violated Section 8(a)(1) of the Act through statements made by several of its supervisors and managers during a preelection campaign in January 2006.2 The consolidated complaint also alleged that the Respondent violated Section 8(a)(1) and (3) of the Act by refusing to permit its employee Lee Mabry to return to work from leave for a work-related injury on December 21, 2005, and again on April 10 because of his activities on behalf of the Union. In connection with this allegation, the consolidated complaint alleged that the Respondent discriminatorily relied upon a new light-duty policy and job description that purportedly were formulated during Mabry’s absence. The Respondent filed its answer to the consolidated complaint on May 15, denying that it committed the unfair labor practices alleged in the complaint and asserting several affirmative defenses. The Respondent also objected to the inclusion of “a Questor Company” in the Respondent’s name.

By Order dated May 22, the consolidated complaint was further consolidated with objections that had been filed by the Union to the election conducted on January 20 in Case 34–RC–1925. The petition in that case had been initially filed by the Union on October 22, 2001, and an election had been conducted on November 29, 2001, pursuant to a Decision and Direction of Election issued by the Board’s Regional Director on November 14, 2001. The Union had filed objections and unfair labor practice charges based on conduct preceding that election. The election conducted on January 20 was a stipulated rerun election. As will be discussed in more detail later, the Union’s objections that were set for hearing in the May 22 Report on Objections included conduct alleged in the consolidated complaint as unfair labor practices during the January preelection period; conduct during the same period that was not alleged to be an unfair labor practice; and conduct that had been the subject of unfair labor practice charges that occurred during the period between the first election in 2001 and the notice of the rerun election. Some of these earlier unfair labor practice charges had been settled and others were litigated and resulted in the Board Order reported at 347 NLRB No. 41 (2006). The Board, in an Order dated August 23, after considering the Respondent’s exceptions to the Objections Report, affirmed the Regional Director’s determination that a hearing on the Union’s objections was warranted and remanded Case 34–RC–1925 for hearing.

On May 17, the Union filed the charge in Case 34–CA–11504, which was amended on July 31. On August 3, a complaint issued in that case alleging that the Respondent, through its Operations Manager Fred Macey, committed additional violations of Section 8(a)(1) of the Act during the preelection period in January 2006. On the same date, an order further consolidating cases issued to consolidate Case 34–CA–11504 with the previously issued consolidated complaint and objections report.3 The Respondent filed its answer to the new complaint on August 17, again objecting to inclusion of “a Questor Company” in the caption and denying that it committed the unfair labor practices alleged. The Respondent also asserted the same affirmative defenses that had been raised in its answer to the original consolidated complaint.

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

Findings of Fact

i.  jurisdiction

The Respondent, a corporation, manufactures frozen dough and other bakery products at its facility in North Haven, Connecticut, where it annually purchases and receives goods valued in excess of $50,000 directly from points located outside the State of Connecticut. The Respondent admits4 and I find that it 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.  Background

1.  The Respondent’s name

As noted above, the complaints in the instant case alleged that the Respondent is “a Questor Company.” Counsel for the General Counsel stated at the hearing that Questor was the only partner in Chef Solutions LLC, the parent company of Pennant Foods’ parent, CS Bakery Holdings, Inc.5 She cited a leaflet distributed to employees during the January preelection campaign which identified Questor as a major shareholder of the Company and referred to support received from Questor in the Respondent’s efforts to remain competitive. The Respondent, in its answers to the complaints, at the hearing, and in its brief has objected to the General Counsel’s inclusion of Questor in the definition of the Respondent. According to the Respondent’s counsel, no evidence has been offered by the General Counsel or the Charging Party that would justify naming Questor a respondent.

The General Counsel’s position in this case differs from the position it took in the unfair labor practice proceeding before another administrative law judge in November 2005. In that case, the General Counsel stipulated that Questor was merely a shareholder of the Respondent and amended the complaint to delete reference to Questor. Pennant Foods Co., 347 NLRB No. 41, ALJD fn. 1 (2006). In the instant case, General Counsel has offered no evidence that would link Questor, or any supervisor or agent of that entity, with the unfair labor practices alleged to have been committed. More specifically, there is no evidence in this record that would warrant a piercing of the corporate veil to impose liability for any of the alleged unfair labor practices on any individual shareholder or limited liability partner. See White Oak Coal Co., 318 NLRB 732 (1995). Cf. A. J. Mechanical, 345 NLRB 295 (2006), reversed in pertinent part 481 F.3d 804 (D.C. Cir. 2007).

I find, based on the limited evidence in the record, that “Questor,” at most, was a shareholder or owner of the Respondent’s parent company at the time the unfair labor practices were allegedly committed.6 As such, it was not properly named a Respondent because there is no evidence that Questor and the Respondent failed to maintain separate identities and that adherence to the corporate structure in this case would “sanction a fraud, promote injustice, or lead to evasion of the Respondent’s legal obligations.” White Oak Coal Co., supra.  Nor is there any evidence that would establish a single employer, alter ego, or joint employer relationship between Questor and the Respondent. Accordingly, I have amended the caption to delete Questor from the definition of the Respondent.

2.  History preceding the rerun election

The Respondent manufactures frozen rolls and other bakery goods at the North Haven facility involved in this proceeding. Subway Sandwich Shops is the Respondent’s main customer. The Union has been engaged in a determined effort to represent a unit of the Respondent’s production and maintenance employees in North Haven since September 2001. At the time of the hearing in this case, there were approximately 143 employees in the unit. The alleged discriminatee, Lee Mabry, has been involved in the Union’s organizing campaign from the beginning. As part of its effort to organize the Respondent’s employees, the Union embarked on a “corporate campaign” aimed at bringing public pressure on the Respondent to recognize the Union. This campaign included visits by bargaining unit members and union representatives to the corporate offices of the Respondent’s parent and shareholders, such as Questor. In addition, the Union enlisted politicians to hold hearings to “investigate” the Respondent’s treatment of its employees. There is no dispute that Mabry was prominent in this campaign and, as the parties stipulated, was the “face” of the Union in the media.

As noted above, the Union filed a petition seeking to represent the Respondent’s employees on October 22, 2001. An election was held on November 29, 2001, which the Union lost by a vote of 99–63. The Union filed timely objections to the election as well as a number of unfair labor practice charges. The charges were resolved through an informal settlement agreement containing a nonadmissions clause, approved by the Board’s Regional Director over the Union’s objections, on December 12, 2003. It appears that the Union’s election objections were resolved by a stipulation for a new election, which had been held in abeyance until the Union filed a request to proceed in late December 2005. Within a year of the approval of the settlement agreement, the Union filed additional charges which were resolved by execution of a formal settlement stipulation on February 18, 2005, providing for entry of a Board Order with enforcement by the court of appeals. The settlement stipulation also contained a nonadmissions clause. The Union again objected to the settlement, contending that the remedies provided by the agreement were insufficient to dissipate the effects of the Respondent’s alleged unfair labor practices. The Board’s decision approving the formal settlement over the Union’s objections issued on January 10, 2006, shortly before the election at issue in this proceeding.7

At the hearing, I rejected the General Counsel’s proffer of the informal settlement agreement, the formal settlement stipulation, and the order and judgment enforcing the formal settlement on the grounds that the settlement of unfair labor practice charges where the Respondent did not admit it had violated the Act was not relevant to determining whether the Respondent violated the Act as alleged in the instant complaints, or whether the special remedies sought by the General Counsel in this case were warranted, or as proof of objectionable conduct. I adhere to that ruling. See Sheet Metal Workers Local 28 (Astoria Mechanical Corp.), 323 NLRB 204 (1997). However, I have taken administrative notice of the documents for the purpose of establishing the procedural history leading up to the instant proceeding. As I advised the parties when making my ruling at the hearing, if the General Counsel or the Charging Party wished to rely on the conduct alleged in the earlier cases to support the positions taken here, they would have to offer proof of the conduct and not simply rely on the existence of the settlement agreements.8

While the formal settlement agreement was pending before the Board, the Union filed additional unfair labor practice charges against the Respondent which led to issuance of a consolidated complaint on August 31, 2005. That complaint went to trial before Administrative Law Judge Joel Biblowitz in November 2005. Judge Biblowitz issued his decision on January 19, the day before the rerun election, finding that the Respondent violated Section 8(a)(1) of the Act on May 24 and 25, 2005, by threatening unfair labor practice strikers with permanent replacement if they refused to abandon a strike.9 Judge Biblowitz also found that the Respondent violated Section 8(a)(1) and (3) of the Act by issuing written warnings to employee Jack Toporovsky on May 9 and 12, 2005; by removing a laptop computer from the office where Toporovsky worked, and by removing telephones from the maintenance department on May 10, 2005; and by failing and refusing to reinstate Toporovsky and fellow maintenance employee Gregory Borukhovich to their prestrike positions since June 7, 2005. On June 27, 2006, the Board adopted Judge Biblowitz’ decision in its entirety. Pennant Foods Co., 347 NLRB No. 41.

The Respondent’s campaign to convince its employees to vote against union representation at the January 20 rerun election generated the current round of charges. The Union again lost the election, by a vote of 84–54, and filed timely objections. The Union also sought, as a remedy for the charges it filed, a Gissel bargaining order.10 The General Counsel, while asking for special remedies in light of the history of the case, does not seek such a remedy. At the hearing, I ruled that the Charging Party was precluded from seeking a bargaining order because of the General Counsel’s conscious decision to refrain from seeking such a remedy. See ATS Acquisition Corp., 321 NLRB 712 fn. 3 (1996).

B.  The 8(a)(1) Allegations

1.  Case 34–CA–11504

The sole allegation in this complaint is that the Respondent, through Fred Macey, its operations manager at the time,11 violated Section 8(a)(1) of the Act in December 2005 or January 2006 by threatening employees with retaliation if they talked about the Union and engaged in union activity, and prohibited employees from talking about the Union and engaging in union activities. This allegation is based upon an incident involving Macey and former employee Gustavo Caporal, who was the General Counsel’s sole witness in support of this allegation. Caporal was terminated by the Respondent on May 4 for allegedly making false entries in company records regarding the temperature of frozen dough being loaded onto trucks for shipment. Caporal, in his testimony, disputed the Respondent’s claims against him, suggesting that he may have been set up to be terminated. However, the allegations in this charge relating to his discharge were dismissed by the Regional Office and not appealed by the Union.

As to the specific allegation at issue, Caporal testified that, a few weeks before the January 20 election, after he and other employees began campaigning for the Union, Macey approached him as he was walking through the production area on his way back to the warehouse after a break. Macey put his arm around Caporal and said, “Gustavo, you know me,” to which Caporal responded affirmatively. Macey then said he did not want to get into an argument with Caporal, he was just doing his job, but that he just wanted to tell Caporal that he didn’t want Caporal talking with the people in production about the Union.12 Macey told Caporal that he could do this on his breaks or during lunch. Caporal said, “[O]kay,” and the conversation ended. According to Caporal, Macy did not speak to him again about this. Caporal testified that this conversation occurred in English. While acknowledging that he sometimes has difficulty communicating in English, he understands the language fairly well.13 On cross-examination, Caporal admitted that he did not mention this conversation to anyone for almost 6 months, and reported it only after he was fired.

Macey did not deny having a conversation with Caporal before the election about his being on the production floor. Macey testified that he spoke to Caporal in response to complaints he had received from the mixer operator and a supervisor that Caporal was interfering with production. According to Macey, he merely took Caporal aside and told him that he works in the shipping department and should remain there, that there was no reason for him to be talking to employees on the production floor. Macey testified that he told Caporal that he could go to the cafeteria and talk to employees on his breaks. Macey denied mentioning the Union in this conversation, asserting that the complaints he received did not indicate what Caporal was talking about to the employees, only that he was disturbing them while they were working.

The General Counsel argues that Macey’s statements to Caporal were an implied threat of retaliation for talking about the Union and amounted to the promulgation of a discriminatory “no-talking” rule. See, e.g., Flamingo Hotel-Laughlin, 324 NLRB 72, 110 (1997), enf. denied in part on other grounds 148 F.3d 1166 (D.C. Cir. 1998). This argument depends entirely on the credibility of Caporal. Although I do not believe Caporal fabricated his testimony, I am reluctant to credit his testimony regarding this conversation. As noted previously, Caporal is not fluent in English and there is a real possibility that he misunderstood Macey’s admonition. I also note the absence of evidence that other employees were prohibited from “talking” about the Union, and the absence of evidence that the Respondent customarily allowed employees from other departments to come onto the production floor and engage production employees in nonwork-related conversation while they were working. Caporal’s testimony without any supporting evidence is thus not sufficiently reliable to support the allegation in the complaint. Moreover, although I did not find Macey a credible witness on other matters, his testimony regarding the conversation with Caporal had the ring of truth. I find it more probable than not that, as Macey testified, he simply reminded Caporal that he needed to remain in his work area unless he was on break and that he should not disturb other employees who were working.

Based on the above, I have determined that the General Counsel has failed to meet his burden of proof on this allegation. Because this is the only unfair labor practice allegation in Case 34–CA–11504, I shall recommend that the complaint in that case be dismissed in its entirety.

2.  Allegations involving Supervisor Rodriguez

The consolidated complaint in Case 34–CA–11385 and 34–CA–11417 alleges, at paragraphs 7 and 8, that the Respondent, through its admitted supervisor, Jennifer Rodriguez, violated Section 8(a)(1) of the Act by interrogating employees and threatening them with loss of employment and closure of the facility if they selected the Union to represent them.14 Respondent has denied these allegations. The General Counsel’s sole witness in support of these allegations was former employee Ricardo Rodriguez, who testified to two encounters with Supervisor Rodriguez in the weeks preceding the January election.15

Ricardo Rodriguez was employed by the Respondent from October 31, 2005, until he voluntarily quit in April or May, a few months after the election. He was a quality control inspector on the second shift. Jennifer Rodriguez was his immediate supervisor. Ricardo Rodriguez testified that Supervisor Rodriguez called him into her office on January 10 at about 4 or 5 p.m. No one else was present.16 According to Ricardo Rodriguez, after initially talking about work-related issues, Supervisor Rodriguez asked him what he knew about the Union. Ricardo Rodriguez told her that some people had spoken to him about it and that he had a relative who was in a union. The supervisor then asked if he knew that there was a union trying to get into the factory. She mentioned that there was an election coming up and told Ricardo Rodriguez that she wanted him to vote “no.”

Ricardo Rodriguez testified that Supervisor Rodriguez also told him, in this conversation, that if the Union got into the Company, the employees could lose their medical benefits and that the Company’s “open-door policy” could end. She told him that the Union would decide what the medical benefits would be. Ricardo Rodriguez also recalled that his supervisor told him the Union could end up causing the factory to close and she gave as an example a company in nearby Meriden, Connecticut, that made car parts and was closing. Ricardo Rodriguez asked Supervisor Rodriguez if it was the same union that was trying to get into the Respondent’s facility and she said it was. According to Ricardo Rodriguez, Supervisor Rodriguez did not explain how the Union could cause the factory to close. Ricardo Rodriguez told his supervisor that he had worked at the factory that was closing for about a week and left because he heard rumors that it was closing. He told her he did not know why the factory was closing. On cross-examination, Ricardo Rodriguez conceded that Jennifer Rodriguez did not say directly that the Respondent was going to close if the Union came into the factory. He also recalled that, at the end of the meeting, Jennifer Rodriguez asked him to think about it and said that she would like him to vote “no.”

Ricardo Rodriguez testified to one other conversation with Jennifer Rodriguez that occurred about a week before the election. This conversation, also in Spanish, took place in her office with no one else present. Again, after initially discussing a work issue, she asked him how things were going on the floor. When Ricardo Rodriguez asked her what she meant, Jennifer Rodriguez replied, “[Y]ou know, the Union.” Ricardo Rodriguez told her that things were good, that some people had talked to him about it saying good things about the Union while others said bad things about it. Ricardo Rodriguez told her he had made up his mind because he did not want to lose benefits. Jennifer Rodriguez told him, “[W]hen you vote, make sure you put a big X where it says no.”

Jennifer Rodriguez testified for the Respondent. She has been employed by the Respondent for more than 10 years and had been the supervisor of sanitation and quality control for about 3-1/2 years at the time of the hearing. She testified that she “did not, at any time talk to Ricardo Rodriguez about the Union.” She repeated this answer, as if by rote, in response to each leading question from counsel as to whether she made the statements attributed to her by Ricardo Rodriguez. According to Jennifer Rodriguez, she only spoke to Ricardo Rodriguez about production. Jennifer Rodriguez acknowledged that she speaks Spanish when talking to the Respondent’s Spanish-speaking employees.17 Jennifer Rodriguez also testified that, in early January, after learning of the rerun election, she attended a meeting with Price and the Respondent’s lawyers at which the supervisors and managers were instructed about how to conduct themselves lawfully during the campaign. She recalled being told not to have meetings with employees about the Union. The supervisors were also told that they could answer employees’ questions if they knew the answer. Otherwise, the supervisor was to refer the employee to human resources.

As between these two witnesses, I found Ricardo Rodriguez to be the more credible witness. Jennifer Rodriguez’ rote denials were not persuasive. In addition, her testimony on another matter, the preparation and distribution of the disputed job descriptions, was deliberately misleading. For example, at first she testified that Maria Giaimo gave her the new job descriptions. Later, when the Respondent’s counsel pointed out that Giaimo did not work there when the job descriptions were supposed to have been created, she changed her testimony. At another point in her testimony, Jennifer Rodriguez testified that she didn’t remember if Operations Manager Macey read from his power point presentation line by line, yet she was certain he didn’t deviate from it. I also noted her evasiveness when answering questions on cross-examination. In total, it appeared that she formulated her answers to advance whatever position the Respondent was taking on an issue. In contrast, Ricardo Rodriguez appeared to be candid with his answers, attempting as best he could to recall events and conversations. Although the Respondent attempted to show that he was biased against the Respondent because he had complained about Jennifer Rodriguez’ supervision in his resignation letter, I did not detect any bias in his testimony. Moreover, contrary to the Respondent’s argument, Ricardo Rodriguez did refer to the unfair labor practice allegation in his resignation letter, when he complained that the Respondent had violated his rights in the election by telling him to vote “no.” Although he did not name his supervisor as guilty of this affront, it is clear from his testimony that, on two occasions, she told him to vote “no.”

Having credited Ricardo Rodriguez, I find, based on his testimony, that the Respondent violated Section 8(a)(1) when his supervisor called him into her office on two occasions and interrogated him about the Union. Ricardo Rodriguez was not an open and notorious union supporter when Jennifer Rodriguez first asked him, on January 10, what he knew about the Union. Nor had he exhibited any prounion sympathies when she called him in again, a week before the election, and asked him how things were going with the Union on the shop floor. Jennifer Rodriguez’ questioning of her subordinate was not part of an isolated and spontaneous conversation but appears to have been deliberately calculated to ascertain Ricardo Rodriguez’ union sympathies. The questioning was all the more coercive because it was coupled with an admonition to vote “no” and occurred in the context of an implied threat of plant closure if the Union prevailed in the upcoming election. Accordingly, under the totality of circumstances, including the Respondent’s history of unfair labor practices, I conclude that Jennifer Rodriguez’ interrogation of Ricardo Rodriguez violated the Act as alleged in the complaint. Medcare Associates, 330 NLRB 935, 939–940 (2000); Sunnyvale Medical Center, 277 NLRB 1217 (1985). Cf. Heartshare Human Services of New York, 339 NLRB 842, 843–844 (2003).

As intimated above, I have also found, based on Ricardo Rodriguez’ credited testimony, that Respondent unlawfully threatened employees with plant closure when Jennifer Rodriguez told him, without explanation, that the Union could end up causing the Respondent to close the facility.18 Although her statement did not directly threaten that the Respondent would close the plant if the Union won the election, she clearly implied that would be the result. This prediction was not based on any objective facts but rather appeared to be based solely on the Union’s history at another nearby facility. Without any further explanation, an employee could reasonably believe that the Respondent would rather close the plant than deal with this Union. The Board and the courts have historically found such statements unlawful NLRB v. Gissel Packing Co., 395 U.S. 575 (1969); Homer D. Bronson Co., 349 NLRB No. 50, slip op. at 2–3 (2007); Daikichi Sushi, 335 NLRB 622, 623–624 (2001). Accordingly, I find that the Respondent has violated the Act as alleged in the complaint.

3.  Alleged threat by Price

The consolidated complaint in Cases 34–CA–11385 and 34–CA–11417 alleges, at paragraph 9, that the Respondent, through Plant Director Price, threatened employees with loss of employment if they selected the Union as their representative. The evidence offered at the hearing indicates that this threat is alleged to have occurred during an employee communication meeting Price held with employees in early January, shortly after the rerun election was announced. The main witness for the General Counsel in support of this allegation is Gregory Borukhovich, one of the unfair labor practice strikers found to have been unlawfully denied reinstatement in the earlier unfair labor practice proceeding before Judge Biblowitz.

Borukhovich testified that he attended a meeting in the lunchroom with about 20–30 other employees, in early January, at which Price informed employees of a wage increase and improvements in benefits.19 Price also talked about the Respondent’s accomplishments in the past year. During the question and answer portion of the meeting, after Price mentioned a letter he sent to the employees about the recent holidays, Borukhovich spoke up, saying, “[W]hat holiday, I had one day off.” Price then mentioned the upcoming election and told the employees that he wanted to work with them and that, if they wanted to work with him, to vote “no.” At that point, Borukhovich asked, “[I]f I vote ‘yes’, will you fire me?” According to Borukhovich, Price did not answer this question. Instead, he became annoyed and told Borukhovich, “[T]his is my meeting. I am paying for this meeting.” Borukhovich admits he also got angry but claimed he could not recall what he said. He acknowledged that he and Price argued back and forth to the point he stopped paying attention to what was said. The only thing he remembered clearly was the above-quoted question he asked Price, which initiated the argument, and the fact that Price did not answer the question. On cross-examination, Borukhovich denied that Price said the election would be by secret ballot. However, he acknowledged that Price did say at one point that “no one will know how you voted.”

The General Counsel called two other witnesses to “corroborate” Borukhovich’s testimony. Jack Toporovsky, the other unfair labor practice striker who was found to have been unlawfully denied reinstatement in the prior case, testified that he was at this meeting and recalled there being an exchange between Borukhovich and Price, but he did not recall what was said. In his pretrial affidavit, Toporovsky had stated that he did not recall being present at any meeting at which Borukhovich spoke up about whether he would be fired if he voted for the Union. Luther Harris, who had been employed by the Respondent for 17 years when he testified at the hearing, recalled entering the meeting when it was already in progress. He did recall Borukhovich speaking up at the meeting after Price mentioned the upcoming election. When Price told the employees they had a right to vote for the Union but asked them to vote “no,” Borukhovich asked, “[I]f I vote yes, will you fire me?” Price did not answer. According to Harris, Borukhovich then said, “I’m going to vote for the Union, you fire me.” Price still did not answer this question. Instead, Price said, “[T]his is my meeting and I’m not going to talk about the Union at this time.” Price then changed the subject and went on with the meeting.20

Price testified for the Respondent regarding this allegation. Price recalled holding an employee communication meeting in January at which Borukhovich got up and started to make a statement during the question and answer portion of the meeting. Price admitted cutting him off by saying, “[T]his is my meeting. If you have a question, ask it, but don’t make statements.” According to Price, Borukhovich started to make his statement again and Price again cut him off. Finally, Borukhovich sat down and the meeting continued. Despite being able to recall the interruption and his response, Price surprisingly could not recall what Borukhovich said before he cut him off. Despite this lack of memory, Price was able to deny that Borukhovich said, “[I]f I vote yes, you fire me,” or words to that effect. The Respondent called no other witnesses who were at this meeting. Jennifer Rodriguez, who was identified by other witnesses as being at this meeting, was not asked any questions about it.

There is very little dispute regarding the facts of this allegation. All witnesses who testified recalled Borukhovich speaking up at the meeting and Price cutting him off by saying, “[T]his is my meeting,” or words to that effect. Although Price claimed he could not recall what Borukhovich said, I find his lack of recall not credible. Borukhovich’s testimony that he asked Price if he would be fired for voting yes is corroborated by Harris, a long-term employee of the Respondent whom I found to be very credible. There is no dispute that, whatever Borukhovich said, Price did not respond to it directly. The issue remains, however, whether Price’s silence, in the face of such a statement, amounts to ratification or adoption of the statement and a threat of job loss for voting for the Union.

The General Counsel and the Charging Party argue that Price’s failure to expressly disavow the suggestion in Borukhovich’s question that a vote in favor of the Union would lead to his termination amounts to agreement with the statement. According to the General Counsel, Price’s silence reinforced the message that, if employees wanted to work with him to improve the Company, they would vote “no.” The only case cited by the General Counsel in support of this argument is Homer D. Bronson Co., supra, where the Board relied on an exchange between an employee and the president of the company to establish that the employer’s statements at a meeting threatened plant closure. In that case, however, the employer’s president did not remain silent when the employee asked if he was saying that the company would move or close if the Union came in. There, the president responded, “[I]t could happen.” This is a far cry from the situation here. As admitted by Borukhovich, not only did Price not respond to the question, but he reminded the employees that “no one will know how you voted.” In addition, Price interrupted Borukhovich, cutting off his question, by stating that it was Price’s meeting, attempting to get the meeting back on track. Under all the circumstances, I can not find that Price’s silence amounted to an unlawful threat, express or implied, that a vote for the Union would result in loss of employment. Accordingly, I shall recommend that this allegation be dismissed.

4.  Alleged threats during the Respondent’s preelection
campaign meetings

There is no dispute that, as part of its campaign to convince the employees to vote against the Union, the Respondent held four series of meetings in the weeks before the election, each one on a different topic conducted by a different member of management. All of the meetings followed the same format with the designated speaker using a power point presentation prepared with assistance of counsel. At each meeting, there was an interpreter to translate the statements made by the management representative from English to Spanish. The meetings were held in a conference room with groups of 15–20 employees. The meetings lasted from 25–40 minutes. According to Brian Glancey, the Respondent’s senior director of human resources at the time, the speakers were instructed to read from the power point verbatim, not to deviate from the scripted presentation, and not to allow for questions.21

The consolidated complaint in Cases 34–CA–11385 and 34–CA–11417 alleges that statements made by Glancey at his series of meetings unlawfully conveyed to employees that their selection of the Union would be futile. The consolidated complaint further alleges that Macey, the Respondent’s operations manager at the time, threatened employees with loss of benefits at his series of meetings. Although Price and Tom Maruri, the Respondent’s vice president of operations, conducted the other two series of meetings, there are no allegations in the complaint regarding anything said at these meetings.

a.  Macey’s alleged threat

Macey conducted the first series of meetings, sometime during the second week of January. The General Counsel relies on the testimony of three witnesses to establish the violation, i.e., Ricardo Rodriguez, Toporovsky, and mixer operator Dave Armstead, a 21-year employee of the Respondent. All three claim that, despite whatever instructions he had, Macey deviated from the power point presentation and spoke extemporaneously during the meeting. Ricardo Rodriguez and Toporovsky attended the same meeting, at approximately 4 or 5 p.m. on January 11. Both recalled that Supervisor Jennifer Rodriguez was at their meeting. Toporovsky recalled the meeting lasting about 40 to 45 minutes. Although Rodriguez testified that the meeting was long and tiring, he did not give a length of time it lasted. Armstead, who works on first shift, attended a different meeting. He recalled that the meeting he attended lasted about an hour.

Ricardo Rodriguez testified that, during the meeting he attended, Macey said, “[I]f you don’t want to lose your medical benefits, you will vote ‘no’” and “[Y]our 401 (k) will be gone,” and “[I]f you don’t want to lose your 401(k), you will vote ‘no’.” According to Rodriguez, Macey did not explain why their benefits would be “gone.” Rodriguez conceded that Macey said a lot of other things in the meeting that he could not remember. According to Ricardo Rodriguez, the most significant thing he remembered from the meeting was Macey’s use of the command, “you will vote no” after almost every statement he made. On cross-examination, Rodriguez testified that Macey described the Respondent’s current health insurance benefits as good and asked the employees why they would want to lose that. Macey went on to say that, with a Union, that might happen and the employees would have to take whatever the Union wanted. Also on cross-examination, Ricardo Rodriguez was asked to review a document purporting to be the power point presentation used by Macey. Although Rodriguez testified that he did not recall seeing all of the pages in the document, he acknowledged that at least part of the proffered exhibit was shown during the meeting.

Toporovsky’s recollection of the meeting differed slightly from that of Ricardo Rodriguez. He testified that the theme of Macey’s meeting appeared to be to tell people to vote “no” by pointing out the Union’s weak spots. He recalled Macey talking about union-represented employees at General Motors losing their jobs and about other unionized employers in the area shutting down. He then testified that Macey said that the Respondent’s employees could lose their health insurance and 401(k) because the Union would come in with their own health and pension benefits. He did not recall Macey saying that these benefits would be subject to bargaining. According to Toporovsky, that was said at another meeting. Like Ricardo Rodriguez, Toporovsky distinctly remembered Macey repeatedly saying “vote no.” Also, as with Ricardo Rodriguez, Toporovsky did not recognize the document proffered by the Respondent as the complete power point presentation Macey used. He did recall that Macey’s statement about losing medical and 401(k) benefits was not on any power point slide but rather was said when Macey elaborated on a statement in one of the slides.

Armstead testified that Macey told the employees at his meeting that their Blue Cross/Blue Shield insurance would be gone if the Union came in because the Union would want the employees to see a union doctor. Armstead recalled that Macey said that everything would be subject to bargaining, that everything would be wiped clean, that the employees would have to start from the beginning, and they could lose. He recalled further that Macey said the employees either could or would lose their 401(k) benefits, although he was not certain about this. Armstead also testified that Macey told employees that with a union, there would be shop stewards and they would no longer be able to go directly to him with a problem. If an employee had a problem, they would have to talk to the steward and, if the shop steward didn’t like you, he might not bring the problem to Macey. As did Ricardo Rodriguez and Toporovsky, Armstead clearly recalled Macey repeatedly telling the employees to “vote no.” According to Armstead, he spoke up at one point, saying, “[W]e could also vote “yes,” to which Macey responded that it was his meeting, don’t disrespect him. When Armstead tried again to point out that employees could vote “yes,” Macey told him if he disrupted the meeting again, he would be asked to leave. On cross-examination, Armstead conceded that he could not recall everything that Macey said which deviated from what was on the power point slides and admitted that he did not pay close attention to what Macey was saying because he had already made up his mind. However, he re-affirmed his testimony on direct, stating that he had a clear recollection of the statements Macey made regarding the loss of benefits.

Macey, when called as a witness by the Respondent, specifically denied making the statements attributed to him by the General Counsel’s witnesses.22 He testified that he merely read the slides in the power point and made no additional comments. Although some of the power point slides had words and phrases, such as “vote no,” printed in bold type, Macey denied emphasizing these statements when he read the slides. He also claimed, somewhat disingenuously, that the purpose of his presentation was not to urge the employees to vote no, despite the appearance of this admonition in the slides. According to Macey, he began the meeting by telling the employees he was there to provide them with information and that he would not be taking questions. He told the employees that, if they had questions, they could ask them at another time. He did corroborate Armstead’s testimony regarding Armstead’s interruption and his response and recalled that Borukhovich had also interrupted another meeting by making the same statement he made during Price’s employee communication meeting about a week earlier. According to Macey, each of his meetings lasted 30 minutes.

The only witness the Respondent called to “corroborate” Macey’s denial was Jennifer Rodriguez.23 Jennifer Rodriguez denied that Ricardo Rodriguez and Toporovsky were at the meeting she attended. She specifically denied that Macey made the alleged threats attributed to him by these witnesses and denied further that he deviated from the scripted power point presentation. However, she admitted that she could not recall whether he read the script “line-by-line.” Jennifer Rodriguez also exhibited poor recall regarding other details of the meeting, including who else was at the meeting she attended.

In addition to the testimony of Macey and Jennifer Rodriguez, the Respondent proffered the scripted power point presentation as part of its defense to this unfair labor practice allegation. As to be expected, nothing on the face of the document amounts to an unfair labor practice under current Board law. Instead, the power point slides contain information about the election, urge employees to vote “no,” posit the loss of 30,000 jobs at GM as the reason the Union is seeking to represent the Respondent’s employees, discusses the role of shop stewards (called “Union pushers”) and the “control” they and the Union would exercise over employees work and lives if the Union were successful, refers to unions’ history of “embezzlement, theft . . ., etc.” and, at the end, asks the employees if they are willing to “risk it.” None of the power point slides in evidence mention the potential loss of medical or 401(k) benefits. The only reference to these benefits is on the following slide, which appears toward the end of the presentation:

How does a Union Make its Money

·    Through dues, fines and assessments.

·    By attempting to control your health insurance premiums.

·    By attempting to control your incentives, bonuses, etc. . . . .

·    By attempting to control your 401k monies.

 

Thus, whether the Respondent committed this alleged unfair labor practice turns initially on whether the testimony of the General Counsel’s witnesses, that Macey did not limit himself to the scripted presentation, is credible.

Having carefully considered the matter, I am unable to credit Macey’s testimony that he merely read the script and did not say anything beyond what was on the slides. I note that Jennifer Rodriguez, whom I have already found not to be a credible witness, did not effectively corroborate this testimony. Although she claimed that Macey did not deviate from the script, she admitted not being able to recall if he read it “line-by-line.” Moreover, if Macey had simply read what was on the slides, the meeting could not have lasted the thirty minutes he claims, and certainly not 40 minutes to an hour, as the General Counsel’s witnesses recalled. In fact, it takes about 5 minutes to read through the exhibit purporting to be the power point presentation, if one reads it at a pace one would expect to be used in a meeting of this nature. Even allowing for time for the interpreter to translate what Macey was saying, the process could not have consumed 30 minutes, unless Macey elaborated on the points raised in the presentation.24 Finally, I note the natural human tendency to extemporize from a prepared script in situations where an individual is speaking on a matter of significance and is trying to make a point, or sell an idea.

Having found that Macey did not limit himself to the script, at least at the two meetings attended by the General Counsel’s witnesses, I must determine whether he made the statements attributed to him by these witnesses and whether such statements amount to a threat of loss of benefits in violation of the Act. Because I have discredited Macey’s claim that he limited his statements at the meeting to what was in the script, I find his denial of the alleged threat unpersuasive. I do not corroborate any of Jennifer Rodriguez’ testimony about this meeting. As with her testimony regarding the conversation with Ricardo Rodriguez and her testimony regarding the purported job descriptions, I find that she was simply saying what was expected of her and was not candid in her testimony.25 At the same time, the testimony of the General Counsel’s witnesses was not free from doubt. I note, in particular, the lack of context to the statements they recalled from the meeting. Although all recalled the meeting lasting a considerable amount of time, they recalled very little of what was said. In addition, on cross-examination, counsel for Respondent was able to undermine some of their direct testimony by getting the witnesses to acknowledge either that they were not paying attention, or that they had confused several meetings, or that their memory was not clear. At the same time, I am struck by the fact that all three recalled very similar statements by Macey, which they adhered to during somewhat lengthy cross-examination.

After careful consideration, I have decided to credit the General Counsel’s witnesses and find that, at the two meetings conducted by Macey that they attended, he elaborated on the points raised in the power point by telling employees that, if they selected the Union, they could lose their current health and 401(k) benefits because the Union would want to have their own such benefits. This statement was most likely made in connection with the point made in the slide that unions make their money through such fringe benefit funds and to emphasize the theme of Macey’s meeting, i.e., that employees would “lose control” if they were represented by a union. Whether such statements violate the Act turns on whether the message conveyed to employees is that their wages and benefits are threatened, not because of the uncertainties of collective bargaining, but simply because the employees selected a union to be their bargaining representative. Federated Logistics & Operations, 340 NLRB 255 (2003), enfd. 400 F.3d 920 (D.C. 2005), and