Summary of NLRB Decisions for Week of January 13 - 17, 2025
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
Public Service Company of New Hampshire d/b/a Eversource Energy (01-CA-333259; 374 NLRB No. 17) Manchester, NH, January 13, 2025.
The Board granted the General Counsel’s Motion for Summary Judgment in this test-of-certification case on the ground that the Respondent failed to raise any issues that were not, or could not have been, litigated in the underlying representation proceeding in which the Union was certified as the bargaining representative.
Charge filed by International Brotherhood of Electrical Workers, Local 1837. Chair Wilcox and Members Kaplan and Prouty participated.
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Salem Village Nursing & Rehabilitation Center, LLC (13-CA-336228; 374 NLRB No. 18) Joliet, IL, January 17, 2025.
The Board granted the General Counsel’s Motion for Default Judgment based on the Respondent’s failure to file an answer to the complaint. The Board found that the Respondent violated Section 8(a)(5) and (1) by failing to offer the Union an opportunity to bargain over the effects of its decision to close its facility and by failing to provide the Union with requested information.
Charge filed by United Food and Commercial Workers International Union, Local 1546. Chair Wilcox and Members Kaplan and Prouty participated.
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Unpublished Board Decisions in Representation and Unfair Labor Practice Cases
R Cases
Jonna Corporation, d/b/a Premier Recycle Company (32-RD-336679) San Jose, CA, January 15, 2025. The Board denied the Petitioner’s Request for Review of the Regional Director’s Decision Dismissing Petition as it raised no substantial issues warranting review. The Board found that the Regional Director properly concluded that the causal nexus between the Employer’s multiple alleged acts of unlawful misconduct, including hallmark violations, and the employees’ subsequent dissatisfaction, was objectively established without the need for a hearing. The Board observed that a hearing is not required in every case in order to assess whether the alleged unfair labor practices result in a finding of taint of a decertification petition under Master Slack, 271 NLRB 78 (1984). Member Kaplan would grant review, reverse the Regional Director's decision to dismiss the decertification petition, and order an election, observing that the Regional Director should not have concluded that there was a causal connection between the unfair labor practice allegations in the complaints and the decertification petition without first holding an evidentiary hearing. Petitioner—an individual. Union—International Brotherhood of Teamsters, Local 853. Chair Wilcox and Members Kaplan and Prouty participated in the decision.
Regal Cinemas, Inc. (19-RC-344825) Spokane, WA, January 17, 2025. The Board denied the Employer’s Request for Review of the Regional Director’s Decision on Objections and Certification of Representation as it raised no substantial issues warranting review. In denying review, the Board emphasized that the Regional Director acted in accordance with the Board’s Rules and Regulations and therefore did not err by rejecting the Employer’s offer of proof because it was not E-filed. Petitioner—Teamsters Local Union 690. Chair Wilcox and Members Kaplan and Prouty participated.
C Cases
River City Asphalt, Inc. (18-CA-280068) Shakopee, MN, January 14, 2025. No exceptions having been filed to the November 20, 2024 Supplemental Decision of Administrative Law Judge Charles J. Muhl’s determining of the amounts of backpay due the employees and recommending that the Respondent pay such amounts. The Board adopts the findings and conclusions of the judge as contained in his Supplemental Decision, and orders that the Respondent pay the amounts set forth in the judge’s Supplemental Decision. Charge filed by an individual.
Ashland Hospital Corporation, d/b/a Ashland Hospital Corporation, d/b/a King’s Daughters Medical Center, a wholly owned corporation of Royal Blue Health, LLC and Ashland Hospital Corporation, d/b/a UK King’s Daughters Medical Center, a wholly owned corporation of Royal Blue Health, LLC, and its parent company Beyond Blue Corporation (09-CA-308275 and 09-CA-308334) Ashland, KY, January 16, 2025. The Board denied the Respondent’s Motion for Summary Judgment, finding that as the Respondent failed to establish that it was entitled to judgment as a matter of law. Charges filed by Service Employees International Union (SEIU), District 1199. Chair Wilcox and Members Kaplan and Prouty participated.
RadNet Management, Inc., d/b/a San Fernando Valley Advanced Imaging Center (31-CA-235878) Los Angeles, CA, January 17, 2025. The Board denied the Respondent’s Motion to Reopen the Record and Motion to Remand to Regional Director the Board’s Decision and Order reported at 373 NLRB No. 58 (2024). The Board determined that the Respondent proffered evidence of alleged misconduct by the unlawfully laid-off employee is instead appropriately raised at the compliance stage of the proceedings. Charge filed by National Union of Healthcare Workers. Chair Wilcox and Members Kaplan and Prouty participated.
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Appellate Court Decisions
No Appellate Court Decisions involving Board Decisions to report.
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Administrative Law Judge Decisions
Yotel Boston (01-CA-302444; JD-03-25) Boston, MA. Administrative Law Judge Michael P. Silverstein issued his decision on January 13, 2025. Charge filed by UNITE HERE Local 26.
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