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Summary of NLRB Decisions for Week of June 10 - 14, 2024

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

Governed United Security Professionals (Golden SVCS, LLC)  (05-CB-299530; 373 NLRB No. 66)  Washington, DC, June 11, 2024.  Errata issued June 12, 2024.  Errata   Amended Decision.

The Board adopted the Administrative Law Judge’s conclusions that, after a majority of bargaining unit employees had voted to deauthorize the union-security clause in the collective-bargaining agreement between the Respondent and the Employer, the Respondent violated Section 8(b)(1)(A) by failing and refusing to recognize employees’ revocations of their dues or fees deduction authorizations and continuing to accept the deductions from the Employer.  Charge filed by an individual.  Administrative Law Judge Michael A. Rosas issued his decision on August 18, 2023.  Members Kaplan, Prouty, and Wilcox participated.

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Commercial Solar Arizona, LLC  (28-CA-288120 and 28-CA-291982; 373 NLRB No. 69)  Scottsdale, AZ, June 14, 2024.

The Board affirmed the Administrative Law Judge’s dismissal of an unlawful discharge allegation, but relied on a different rationale.  The Board found that the General Counsel did not meet her initial burden under Wright Line because the evidence did not establish that the Respondent discharged the alleged discriminatee.  The Board also remanded unlawful work rule allegations for the judge to apply Stericycle, Inc., 372 NLRB No. 113 (2023). However, the Board did not remand the allegation regarding the Respondent’s “Phone, Computer, E-mail and Internet Usage” handbook policy, as the judge properly applied Caesars Entertainment d/b/a Rio All-Suites Hotel & Casino, 368 NLRB No. 143 (2019), to find that the policy was lawful.

Charges filed by an individual.  Administrative Law Judge Ariel L. Sotolongo issued his decision on June 20, 2023.  Chairman McFerran and Members Prouty and Wilcox participated.

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Unpublished Board Decisions in Representation and Unfair Labor Practice Cases

R Cases

Starbucks Corporation  (07-RD-332441)  Grand Rapids, MI, June 11, 2024.  The Board denied the Employer’s Request for Review of the Regional Director’s Decision and Order Dismissing Petition as it raised no substantial issues warranting review.  The Regional Director dismissed the decertification petition, subject to reinstatement, due to a pending unfair labor practice complaint against the Employer seeking an affirmative bargaining order and an extension of the certification year.  Petitioner—an individual.  Union—Chicago & Midwest Regional Joint Board, Workers United/SEIU.  Chairman McFerran and Members Prouty and Wilcox participated.

Arrow Security  (02-RC-342349)  Tarrytown, NY, June 12, 2024.  The Board granted the Party in Interest’s Request for Review of the Regional Director’s Order Denying Motion to Intervene as it raised substantial issues warranting review.  The Board also granted the Party in Interest’s request to stay the election.  Petitioner—Federal Contract Guards of America.  Party in Interest—Local 32BJ, Service Employees International Union.  Chairman McFerran and Members Prouty and Wilcox participated.

The Trustees of Columbia University in the City of New York  (02-UC-305373)  Manhattan, NY, June 14, 2024.   The Board denied the Employer’s Request for Review of the Regional Director’s Order Partially Dismissing Petition as it raised no substantial issues warranting review. Petitioner—Student Workers of Columbia, UAW Local 2710.  Chairman McFerran and Members Prouty and Wilcox participated.

Crothall Healthcare Services  (07-UC-299379)  Detroit, MI, June 14, 2024.  The Board denied the Employer/Petitioner’s Request for Review of the Regional Director’s Dismissal of its unit clarification petition as it raised no substantial issues warranting review.  Unions—American Federation of State, County and Municipal Employees, Council 25, AFL-CIO, Locals 140, 181, and 3695 and Service Employees International Union, Healthcare Michigan CTW.  Chairman McFerran and Members Prouty and Wilcox participated.

C Cases

No Unpublished C Cases Issued.

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Appellate Court Decisions

No Appellate Court Decisions involving Board Decisions to report.

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Administrative Law Judge Decisions

Starbucks Corporation  (09-CA-300652; JD-33-24)  Louisville, KY.  Administrative Law Judge Melissa M. Olivero issued her decision on June 12, 2024.  Charge filed by Chicago & Midwest Regional Joint Board, an affiliate of Workers United SEIU.

Starbucks Corporation  (06-CA-297994 and 06-CA-312721; JD-34-24)  Greensburg, PA. Administrative Law Judge Arthur J. Amchan issued his decision on June 13, 2024.  Charges filed by International Brotherhood of Teamsters, Local Union No. 30.

J.O. Mory, Inc.  (25-CA-309577 and 25-CA-336995; JD-36-24)  Fort Wayne, IN. Administrative Law Judge Sarah Karpinen issued her decision on June 13, 2024.  Charges filed by Indiana State Pipe Trades Association, a/w United Association of Journeymen and Apprentices of the Plumbing and Pipefitting Industry of the United States and Canada, AFL-CIO.

Starbucks Corporation  (10-CA-301421 and 10-CA-311503; JD-35-24)  Augusta, GA. Administrative Law Judge Ira Sandron issued his decision on June 14, 2024.  Charges filed by Workers United, Southern Regional Joint Board.

Starbucks Corporation  (13-CA-316407; JD-37-24)  Chicago, IL.  Administrative Law Judge Susannah Merritt issued her decision on June 14, 2024.  Charge filed by Chicago & Midwest Regional Joint Board, Workers United/SEIU.

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