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Summary of NLRB Decisions for Week of December 19 - 23, 2016

The Summary of NLRB Decisions is provided for informational purposes only and is not intended to substitute for the opinions of the NLRB.  Inquiries should be directed to the Office of the Executive Secretary at 202‑273‑1940.

Summarized Board Decisions

Howard Industries, Inc.  (15-CA-164449; 365 NLRB No. 4)  Laurel, MS, December 21, 2016.

The Board adopted the Administrative Law Judge’s recommended dismissal of allegations that the Respondent violated Section 8(a)(5) and (1) by unilaterally changing its policy regarding which employees were to be given hams during the Christmas season, without first notifying and giving the Union the opportunity to bargain about the policy change.  The judge recommended dismissing the complaint because he found that the Respondent implemented the change after following the procedure set forth in the parties’ collective-bargaining agreement with respect to the implementation of new or modified policies.

Charge filed by International Brotherhood of Electrical Workers, Local 1317.  Administrative Law Judge Geoffrey Carter issued his decision on September 2, 2016.  Chairman Pearce and Members Miscimarra and McFerran participated.

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Wells Enterprises, Inc.  (18-CA-150544 and 18-CB-153774; 365 NLRB No. 7)  Le Mars, IA, December 22, 2016.

The Board adopted the Administrative Law Judge’s conclusions that Respondent Wells Enterprises, Inc. violated Section 8(a)(2) and (1) of the Act by providing Respondent United Dairy Workers of Le Mars proceeds from vending machine and micro-market sales, and that Respondent United Dairy Workers of Le Mars violated Section 8(b)(1)(A) by accepting such financial support.  The Board amended the judge’s remedy to delete requirements that Respondent Wells Enterprises cease recognition of Respondent United Dairy Workers of Le Mars after the Respondents’ current collective-bargaining agreement expired, and that the Respondents cease giving effect to certain provisions of their contract.  Under the circumstances, the Board found that requiring the Respondents to cease and desist from engaging in the unlawful commission arrangement, and to post notices to employees and members, would fully remedy the violations found and thereby effectuate the purposes of the Act.

Charges filed by an individual.  Administrative Law Judge Eric M. Fine issued his decision on June 20, 2016.  Chairman Pearce and Members Miscimarra and McFerran participated.

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Unpublished Board Decisions in Representation and Unfair Labor Practice Cases

R Cases

Green Line Group Inc.  (01-RC-181492)  Boston, MA, December 21, 2016.  A Board majority (Chairman Pearce and Member McFerran) denied the Employer’s Request for Review of the Regional Director’s Decision and Direction of Election, in which the Regional Director found that the members of the petitioned-for unit were statutory employees, rather than independent contractors excluded from coverage of the Act.  Member Miscimarra, dissenting, would have granted review to determine whether the Employer functioned more like a referral agency than an employer.  Petitioner – International Brotherhood of Electrical Workers Local 1228, AFL-CIO.  Chairman Pearce and Members Miscimarra and McFerran participated.

New York Methodist Hospital and MSO of Kings County, LLC, a single employer  (29-RC-172410)  Brooklyn, NY, December 21, 2016.  The Board denied the Employer’s Requests for Review of the Regional Director’s Decision and Direction of Election, Supplemental Decision on Challenges, and Supplemental Decision on Objections and Certifications of Representative, as they raised no substantial issues warranting review.  Petitioner – 1199 SEIU, United Healthcare Workers East.  Chairman Pearce and Members Miscimarra and McFerran participated.

McCabe, Hamilton & Renny Co., Ltd.  (20-RC-175876)  San Juan, PR, December 21, 2016.  The Board denied the Employer’s Request for Review of the Regional Director’s Decision and Direction of Election in which the Regional Director found that the Employer had failed to establish that the petitioned-for dispatchers were statutory supervisors and found that the petitioned-for unit was appropriate.  Dissenting in part, Member Miscimarra would have granted review regarding the supervisory status of the petitioned-for operations supervisors and would apply his dissent in Buchanan Marine, L.P., 363 NLRB No. 58, slip op. at 5 (2015).  Member Miscimarra agreed with his colleagues’ denial of review concerning whether the petitioned-for unit is appropriate, but would not apply the Board’s decision in Specialty Healthcare, 357 NLRB 934 (2011), for the reasons stated in his dissent in Macy’s, Inc., 361 NLRB No. 4, slip op. at 22-23 (2014).  Petitioner – Working Foremen’s and Working Supervisors’ Union, Local 100, International Longshore & Warehouse Union.  Chairman Pearce and Members Miscimarra and McFerran participated.

Magic Valley Electric Cooperative, Inc.  (16-RC-180237)  locations in Texas, December 21, 2016.  The Board denied the Employer’s request to stay the election.  Petitioner – International Brotherhood of Electrical Workers, AFL-CIO, Local Union 66.  Chairman Pearce and Members Miscimarra and McFerran participated.

IGT Global Solutions  (01-RC-176909)  West Greenwich, RI, December 21, 2016.  The Board granted the Petitioner’s Request for Review of the Regional Director’s Decision and Order as it raised substantial issues warranting review.  The Board majority (Chairman Pearce and Member McFerran) granted review as to whether the Regional Director erred, under Sec. 102.66(d) of the Board’s Rules & Regulations, by permitting the Employer to litigate issues contained in its untimely served Statement of Position, and by finding that the petitioned-for unit was inappropriate under Specialty Healthcare & Rehabilitation Center of Mobile, 357 NLRB 934 (2011), enfd. sub nom. Kindred Nursing Centers East, LLC v. NLRB, 727 F.2d 552 (6th Cir. 2013).  Member Miscimarra agreed with his colleagues that the Petitioner raised substantial issues warranting review of the Regional Director’s determination that the petitioned-for unit is not an appropriate unit for bargaining.  In granting review on this issue, however, Member Miscimarra would not apply Specialty Healthcare, for the reasons stated in his dissent in Macy’s, Inc., 361 NLRB No. 4, slip op. at 22-33 (2014).  Member Miscimarra would deny review with respect to the Petitioner’s contention that, because the Employer failed to timely serve its Statement of Position on the Union, it was precluded from litigating the appropriateness of the unit.  In Member Miscimarra’s view, this issue is governed by Sec. 9(b) of the Act (requiring the Board “in each case” to decide what bargaining unit would “assure to employees the fullest freedom in exercising [protected] rights”) and Brunswick Bowling Products, LLC, 364 NLRB No. 96 (2016) (finding it is appropriate for regional directors to make determinations regarding relevant issues, even if they favor the party that failed to comply with the Statement of Position requirement set forth in the Board’s Election Rule).  More generally, Member Miscimarra adheres to his dissenting views regarding the Election Rule, see 79 Fed. Reg. 74430-74460, including his disagreement with provisions in the Rule that purport to preclude the resolution of relevant issues based on non-compliance with the Statement of Position requirements.  Petitioner – International Brotherhood of Teamsters, Local 251.  Chairman Pearce and Members Miscimarra and McFerran participated.

East End Bus Lines, Inc.  (29-RC-168266)  Medford, NY, December 21, 2016.  The Board denied the Employer’s Request for Review of the Regional Director’s Decision and Certification of Representative on the ground that it raised no substantial issues warranting review.  Petitioner – International Brotherhood of Teamsters, Local 1205.  Intervenor – Transit Workers Union of America, Local 252, AFL-CIO.  Chairman Pearce and Members Miscimarra and McFerran participated.

Seattle Children’s  (19-RC-183402)  Seattle, WA, December 22, 2016.  The Board denied the Employer’s Request for Review of the Regional Director’s Decision and Direction of Election on the ground that it raised no substantial issues warranting review.  In denying review, the Board agreed with the Regional Director that Respiratory Educators are technical employees.  Even apart from the Regional Director’s finding that the Respiratory Educators share a community of interest with the employees in the current unit of technicals, the Board found the petitioned-for Respiratory Educators constitute an appropriate voting group for a self-determination election.  Petitioner – United Food and Commercial Workers Union, Local 21. Chairman Pearce and Members Miscimarra and McFerran participated.

The New School  (02-RC-143009)  New York, NY, December 23, 2016.  The Board (Chairman Pearce and Member McFerran, Member Miscimarra concurring) remanded this case to the Regional Director.  A Board majority (Chairman Pearce and Member McFerran) remanded this case for further appropriate action consistent with Columbia University, 364 NLRB No. 90 (2016), including reopening the record, if necessary.  In remanding, the majority rejected the Employer’s argument that the Regional Director should be required to conduct an additional review of the Petitioner’s showing of interest prior to conducting an election.  Although agreeing to the remand, Chairman Pearce would have found, under Columbia University, that the record establishes that student assistants are statutory employees and thus it is unnecessary to remand that issue to the Regional Director.  Member Miscimarra, dissenting in part based on the reasons in his dissenting opinion in Columbia University, 364 NLRB No. 90, slip op. at 22-34 (2016), would have denied review of the Regional Director’s order dismissing the petition, which applied Brown University, 342 NLRB 483 (2004), to find the student assistants in this case are not statutory employees.  Nevertheless, he believed that the parties should have the opportunity to develop a factual record informed by the principles stated in the majority and dissenting opinions in Columbia.  Thus, he concurred in remanding this case to the Regional Director, but, contrary to the majority, he believed the record must be reopened at the request of either party.  Petitioner – Student Employees at the New School—SENS/UAW.  Chairman Pearce and Members Miscimarra and McFerran participated.

New York Methodist Hospital and MSO of Kings County, LLC, a single employer  (29-RC-172398)  Brooklyn, NY, December 22, 2016.  The Board denied the Employer’s Request for Review of the Regional Director’s Decision and Direction of Election, Supplemental Report on Challenges, and Supplemental Decision on Objections and Certifications of Representative, as it raised no substantial issues warranting review.  Petitioner – 1199 SEIU, United Healthcare Workers East.  Chairman Pearce and Members Miscimarra and McFerran participated.

Logan Bus Co., Inc.  (02-RC-163227)  Bronx, NY, December 22, 2016.  The Board denied the Petitioner’s Motion for Reconsideration of the Board’s July 27, 2016 Order denying the Request for Review of the Regional Director’s Decision and Direction of Election, finding that the Petitioner did not demonstrate extraordinary circumstances warranting reconsideration under Section 102.65(e)(1) of the Board’s Rules and Regulations and was also untimely.  Petitioner – International Brotherhood of Teamsters, Local 553.  Intervenor – United Craft and Industrial Workers Union, Local 91.  Chairman Pearce and Members Miscimarra and McFerran participated.

C Cases

THC Orange County Inc. d/b/a Kindred Hospital – Ontario; Kindred Hospital South Bay; Kindred Hospital Ontario; and KND Development 53 LLC d/b/a Kindred South Bay  (31-CA-162635, et al.)  Ontario, CA, December 21, 2016.  The Board denied the petitions to revoke investigative subpoenas duces tecum filed by KND Development 53 LLC d/b/a Kindred South Bay and Kindred Hospital Ontario as untimely filed.  In addition, the Board majority (Chairman Pearce and Member McFerran) found that, even assuming the petitions were timely filed, they were lacking in merit, as the subpoenas sought information relevant to the matter under investigation and described with sufficient particularity the evidence sought, and the Employers failed to establish any other legal basis for revoking the subpoenas.  Member Miscimarra would have denied the petitions to revoke solely on the ground that they were untimely filed.  Charges filed by Service Employees International Union, Local 121RN, and Service Employees International Union, United Healthcare Workers–West.  Chairman Pearce and Members Miscimarra and McFerran participated.

TCT Stainless Steel, Inc. and its alter ego Tempered & Specialty Metals  (07-CA-179856)  Sterling Heights, MI, December 21, 2016.  The Board denied the Employer’s petition to revoke four investigative subpoenas ad testificandum, finding that the subpoenas sought information relevant to the matter under investigation and described with sufficient particularity the evidence sought, and that the Employer failed to establish any other legal basis for revoking the subpoenas.  Charge filed by Local 283, International Brotherhood of Teamsters.  Chairman Pearce and Members Miscimarra and McFerran participated.

TCT Stainless Steel, Inc. and its alter ego Tempered & Specialty Metals  (07-CA-179856)  Sterling Heights, MI, December 21, 2016.  The Board denied the Employer’s petition to revoke a portion of an investigative subpoena duces tecum, finding that the subpoena sought information relevant to the matter under investigation and described with sufficient particularity the evidence sought, and that the Employer failed to establish any other legal basis for revoking the subpoenas.  Charge filed by Local 283, International Brotherhood of Teamsters.  Chairman Pearce and Members Miscimarra and McFerran participated. 

JRN, Inc.  (10-CA-172802)  Columbia, GA, December 21, 2016.  The Board denied the General Counsel’s Motion for Summary Judgment, finding that the General Counsel failed to establish that there were no genuine issues of material fact warranting a hearing and that he was entitled to judgment as a matter of law.  The denial was without prejudice to the General Counsel’s ability to renew the motion before the Administrative Law Judge.  Member Miscimarra found that there may be issues of fact concerning two of the four policies alleged to be unlawful.  Additionally, he would deny the General Counsel’s Motion because he disagrees with the “reasonably construe” test set forth in Lutheran Heritage Village-Livonia, 343 NLRB 646, 647 (2004), and believes that the lawfulness of work rules should be determined by balancing the employer’s legitimate justification for the rule and the potential adverse impact on NLRA-protected activity.  Charge filed by an individual.  Chairman Pearce and Members Miscimarra and McFerran participated.

Potomac Disposal, Inc.  (05-CA-175956)  Gaithersburg, MD, December 21, 2016.  The Board approved a Formal Settlement Stipulation between the Respondent, the Charging Parties, and the General Counsel, and specified actions the Respondent must take to comply with the Act.  Charge filed by Construction and General Laborers Local Union 657, affiliated with Laborers’ International Union of North America, AFL-CIO.  Chairman Pearce and Members Miscimarra and McFerran participated.

Trustone Financial Federal Credit Union  (18-CA-158210, 18-CA-163034, and 18-CA-165634)  Plymouth, MN, December 21, 2016.  The Board remanded the case to Region 18 for appropriate action.

Local 876, IBEW (Newkirk Electric Associates, Inc.)  (07-CD-182456)  Muskegon, MI, December 21, 2016.  The Board granted the request to file and consider a Brief Amicus Curiae.

Air Products and Chemicals, Inc.  (12-CA-181263)  Palmetto, FL, December 22, 2016.  The Board denied the Employer’s petition to revoke an investigative subpoena duces tecum, finding that the subpoena sought information relevant to the matter under investigation and described with sufficient particularity the evidence sought, and that the Employer failed to establish any other legal basis for revoking the subpoena.  Member Miscimarra would grant the petition to revoke the subpoena as to the requests for all employee handbooks, policy guidelines, and work rules, except for the handbook provisions that relate to the issues identified in the subpoena or to the particular employee actions or reasons identified by the Employer as the basis for the discharge at issue.  He would further grant the petition to the extent that the subpoena requests information about non-statutory employees.  Charge filed by an individual.  Chairman Pearce and Members Miscimarra and McFerran participated.

United Security & Police Officers of America  (05-CB-172609)  Washington, D.C., and Oxon Hill, Maryland, December 22, 2016.  The Board approved a Formal Settlement Stipulation between the Respondent Union, the Charging Party, and the General Counsel, and specifying actions the Union must take to comply with the Act.  Charge filed by an individual.  Chairman Pearce and Members Miscimarra and McFerran participated.

Thomas J. Moyle Jr., Inc. d/b/a Moyle Construction  (18-CA-165458)  Houghton, MI, December 23, 2016.  No exceptions having been filed to the September 28, 2016 decision of Administrative Law Judge Charles J. Muhl’s finding that the Respondent had engaged in certain unfair labor practices, the Board adopted the judge’s findings and conclusions, and ordered the Respondent to take the action set forth in the recommended Order.  Charge filed by an individual.

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Appellate Court Decisions

Caravan Knight Facilities Management, Inc., and International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), AFL–CIO, and its Local 1700, Case Nos. 07-CA-081195 and 07-CB-082391 (reported at 362 NLRB No. 196) (6th Cir. decided December 21, 2016)

In a published opinion, the court granted the petition filed by the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, and its Local 1700, for review of the Board’s finding that Local 1700 violated Section 8(b)(1)(A) of the Act by breaching its duty of fair representation owed to an employee who was discharged by the respondent-employer, a janitorial service that contracted to clean the Chrysler assembly plant in Sterling Heights, Michigan.  The court vacated that portion of the Board’s decision finding the breach of the duty of fair representation, and did so without remanding the case.  The respondent-employer did not seek review of the Board’s finding that its coercive interrogation of an employee violated Section 8(a)(1) of the Act.

Reversing the Administrative Law Judge’s dismissal of the duty of fair representation allegation, the Board (Members Miscimarra, Johnson, and McFerran) found that Local 1700 breached its duty by acting arbitrarily or in bad faith in handling the grievance of a discharged employee.  In a series of reported incidents, the employee apparently had threatened her co-workers, and for one of those incidents, the union steward provided a witness statement describing the incident.  The employee was subsequently discharged and the union steward filed a grievance on her behalf.  In finding that Local 1700 breached its duty of fair representation, the Board expressly based its conclusion on the cumulative import of three facts:  (1) that the union steward who handled the grievance had earlier submitted the adverse witness statement that was partly false because it indicated that she personally witnessed the incident, (2) that the steward represented the discharged employee at step 1 of the grievance process without disclosing the adverse statement’s existence, and (3) that the employee remained unaware of the statement throughout Local 1700’s processing of her grievance.

On review, the court (Circuit Judges Gilman, Gibbons, and Stranch) held that the first fact relied on by the Board—that the steward’s witness statement was partly false because she had not personally witnessed the incident—was not supported by substantial evidence.  Rather, the court determined that the credited testimony of two witnesses was not inconsistent with the steward being present in the area when the incident occurred.  The court then concluded that the two remaining facts upon which the Board relied were insufficient to support the violation.

In a concurring opinion, Judge Stranch wrote separately to emphasize that typically remand to the Board would have been appropriate.  However, on this “unusual record,” he concurred in vacating that portion of the Board’s decision finding a breach of the duty of fair representation.

The court’s opinion is here.

Public Service Employer of New Mexico, Board Case No. 28-CA-023391 (reported at 360 NLRB No. 45) (D.C. Cir. decided December 20, 2016)

In a published opinion, the court enforced the Board’s order issued against this New Mexico corporation that purchases, produces, transmits, and sells electricity, for unfair labor practices committed at its coal-fired power plant near Farmington, and its service center in Albuquerque, where various line, radio, meter, and radio technicians are covered by a collective-bargaining agreement administered by their representative, the International Brotherhood of Electrical Workers, Local Union No. 611.

The Board (Chairman Pearce and Members Schiffer and Johnson) found, in addition to several threats against employees and an interrogation that were unlawful under Section 8(a)(1) of the Act, that the Employer committed multiple violations of Section 8(a)(5) and (1).  Those violations included refusing to provide a variety of requested information that is relevant and necessary to the Union’s bargaining duties, making unilateral changes to the contractual grievance process (Member Johnson, dissenting), and refusing to meet with an employee about his racial discrimination complaint unless he renounced his right to union representation.  Before the court, the Employer challenged only those three Section 8(a)(5) findings, and the court granted summary enforcement of the numerous contested unfair labor practices.

Regarding the information requests, which had asked for information on non-unit employees in connection with pending grievances alleging disparate treatment of unit and non-unit employees under company-wide polices, the court held that the requests were properly related to the policies and limited to similarly-situated, non-unit employees.  Concerning the grievance procedure, the Employer argued that it was entitled to unilaterally change the initial, informal step of the process in three ways:  by requiring a second supervisor to attend initial meetings, by requiring that grievances be described with particularity before any oral discussion, and by instructing supervisors not to sign for receipt of written grievances after meeting with union stewards.  The court, agreeing with the Board, held that the parties had a longstanding practice of conducting the informal step with a high degree of informality, and that the unilateral modifications were unlawful because they were material, substantial, and significant changes to that established practice.  Finally, regarding the Board’s finding that the Employer unlawfully refused to meet with an employee about his racial discrimination complaint unless he renounced his right to union representation, the court found the issue a “non-starter” because the collective-bargaining agreement expressly incorporated federal and state prohibitions against racial discrimination, and thus the employee could not be deprived of his right to union representation.

The court’s opinion is here.

UNF West, Inc., Board Case No. 21-CA-129446 (reported at 363 NLRB No. 96) (5th Cir. decided December 20, 2016)

In a published opinion, the court enforced the Board’s order issued against this distributor of natural, organic, and specialty foods for unfair labor practices committed prior to a second representation election held among employees at its warehouse in Moreno Valley, California, to decide whether to be represented by Teamsters, Chauffeurs, Warehousemen, Industrial and Allied Workers of America, Local 166, International Brotherhood of Teamsters.  In a prior case, the Board found that the Employer violated the Act in the months before and after the first election in May 2012, which the Union lost, by, among other things, warning the lead employee organizer on four occasions that it would refuse to negotiate or sign any contract with the Union, that all workers could lose benefits if they selected the Union, that management was looking for a way to fire him, and that his working conditions would not improve unless he stopped complaining to the Union and the Board.  UNF West, Inc., 361 NLRB No. 42 (Sept. 3, 2014) (“UNF West I”), enforced, No. 14-1181 (D.C. Cir. Jan. 15, 2016) (unpublished judgment).

In the present case, the Board (Chairman Pearce and Members Hirozawa and McFerran) found multiple violations of Section 8(a)(1) of the Act.  Those findings included unlawful interrogations and threats by the Employer’s labor consultant who, in private conversations, asked employees about their union support, threatened that their support of the Union would be futile, and threatened that their wages would be reduced if they voted for the Union.  The Board also found unlawful the consultant’s statements made in a captive-audience meeting that made clear to the several attending employees that the Employer could and would unilaterally reduce their wages if the Union won the election.  Rejecting the Employer’s contentions, the Board held that the Administrative Law Judge did not abuse his discretion by requiring a bilingual witness to attempt to testify in English before determining whether he needed a translator, or by excluding irrelevant and speculative evidence.  In light of the Employer’s recidivism, the Board determined that a public notice reading in English and Spanish was necessary to assure employees of their rights and the Employer’s obligations under the Act.

On review, the court agreed with the Board’s findings of unlawful threats and found them supported by substantial evidence.  Regarding findings of coercive interrogation, the court upheld the Board’s application of the factors articulated in Bourne v. NLRB, 332 F.2d 47, 48 (2d Cir. 1964).  In rejecting the Employer’s contention that the Board’s analysis was flawed, the court explained that the “Bourne factors are analytical guiding lights—not a mandate for formalistic analysis,” and that “[n]o single factor is determinative.”

In upholding the Board’s notice-reading remedy, the court took note of the Board’s broad discretion in fashioning remedies and held, based on in-circuit precedent and the prior violations in UNF West I, that, given the Employer’s persistent and repeated misconduct, “‘the Board is warranted in impliedly concluding that such conduct has created a chill atmosphere of fear and, further, in recognizing that the reading requirement is an effective but moderate way to let in a warming wind of information and, more important, reassurance.’”  (Quoting J.P. Stevens & Co. v. NLRB, 417 F.2d 533, 540 (5th Cir. 1969).)

The court’s opinion is here.

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Administrative Law Judge Decisions

International Association of Machinists and Aerospace Workers, District 65, Local 330 (Ingersoll-Rand Company)  (03-CB-168560; JD-119-16)  Cheektowaga, NY.  Administrative Law Judge Thomas M. Randazzo issued his decision on December 19, 2016.  Charge filed by an individual.

Tegna, Inc. d/b/a KGW-TV  (19-CA-148474; JD(SF)-48-16)  Portland, OR.  Administrative Law Judge Mara-Louise Anzalone issued her decision on December 20, 2016.  Charge filed by International Brotherhood of Electrical Workers, Local 48, AFL-CIO.

Merck, Sharp & Dohme Corp.  (06-CA-163815, 05-CA-168541, and 22-CA-168483; JD-118-16)  Riverside, PA.  Administrative Law Judge David I. Goldman issued his decision on December 20, 2016.  Charges filed by United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, Local 10-580, AFL-CIO, CLC; Local 94C, International Chemical Workers Council of the United Food and Commercial Workers International Union, AFL-CIO; and United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, Local 4-575, AFL-CIO, CLC.

Lewanee Stamping Corporation d/b/a Kirchhoff Van-Rob  (07-CA-168498 and 07-CA-172535; JD-120-16)  Tecumseh, MI.  Administrative Law Judge Mark Carissimi issued his decision on December 22, 2016.  Charges filed by Local 3000, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), AFL-CIO.

ETS Oilfield Services, L.P.  (16-CA-172847; JD-121-16)  Robstown, TX.  Administrative Law Judge Sharon Levinson Steckler issued her decision on December 23, 2016.  Charge filed by an individual.

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