Summary of NLRB Decisions for Week of March 3 - 7, 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
No Published Board Decisions Issued.
***
Unpublished Board Decisions in Representation and Unfair Labor Practice Cases
R Cases
No Unpublished R Cases Issued.
C Cases
Mount Sinai Health System, Inc. (02-CA-329471) New York, NY, March 7, 2025. No exceptions having been filed to the December 31, 2024 decision of Administrative Law Judge Michael P. Silverstein’s finding that the Respondent had not engaged in certain unfair labor practices, the Board adopted the judge’s findings and conclusions and dismissed the complaint. Charge filed by an individual.
Interstate Power Tools and Machining, Inc., d/b/a Interstate Rentals (25-CA-323892) Valparaiso, IN, March 7, 2025. No exceptions having been filed to the January 3, 2025 decision of Administrative Law Judge G. Rebekah Ramirez’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 judge’s recommended Order. Charge filed by International Union of Operating Engineers, Local 150, AFL-CIO.
Goke Technology LLC, d/b/a GT Security Services GTS (09-CA-312117) Columbus, OH, March 7, 2025. No exceptions having been filed to the February 5, 2025 decision of Administrative Law Judge Andrew S. Gollin’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 judge’s recommended Order. Charge filed by an individual.
Teamsters Local, 728 (BFI Waste Services, LLC, d/b/a Allied Waste Services of Atlanta/ Republic Services of Georgia) (10-CB-335036) Atlanta, GA, March 7, 2025. No exceptions having been filed to the February 4, 2025 decision of Administrative Law Judge Michael P. Silverstein ’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 judge’s recommended Order. Charge filed by an individual,
***
Appellate Court Decisions
Hood River Distillers, Inc., Board Case No. 19-CA-260013 (reported at 372 NLRB No. 126) (D.C. Cir. Mar. 7, 2025).
In a published opinion, the D.C. Circuit enforced the Board’s order that issued against this liquor distillery with a facility and warehouse in Hood River, Oregon, where a unit of 25 employees have long been represented by Teamsters Local Union No. 670. Among other unfair labor practices, the Board (Chairman McFerran and Members Wilcox and Prouty) held that, during negotiations for a successor contract, Hood River unlawfully implemented its final offer in the absence of a valid impasse, and thereafter engaged in numerous unilateral actions, including changes to wages, paid holidays, health and pension plans, paid time-off and union-access policies, and ceased dues checkoff, all in violation of Section 8(a)(5) and (1). The Board also added the Thryv remedy to its order. Without moving for reconsideration, Hood River sought court review, principally arguing that it had acted in response to a valid impasse in contract negotiations.
On review, the Court (Judges Pan and Childs; Judge Walker, dissenting) upheld the Board’s conclusion that Hood River acted unlawfully in unilaterally implementing its final offer. Applying the substantial-evidence standard of review, the Court noted that “‘few issues are less suited to appellate judicial appraisal than evaluation of bargaining processes or better suited to the expert experience’ of the Board,” quoting Wayneview Care Center v. NLRB, 664 F.3d 341 (D.C. Cir. 2011). Citing record evidence of the parties’ final bargaining session, the Court noted that significant concessions had been made by both sides on wages and a health-care plan, and that Hood River had proposed an additional compromise, all demonstrating that “neither party was at the end of its rope.” Further, the Court agreed with the Board that Hood River had failed to carry its burden of proving its contention that in 2020, at the beginning of the COVID-19 pandemic, the Union had engaged in unjustified delay tactics. Lastly, the Court held that Hood River failed to preserve its challenge to the Board’s Thryv remedy by not presenting it to the Board as required by Section 10(e) of the Act.
The Court’s opinion is here.
***
Administrative Law Judge Decisions
United States Postal Service (07-CA-292942; JD-18-25) Detroit, MI. Administrative Law Judge Christine E. Dibble issued her decision on March 3, 2025. Charge filed by National Association of Letter Carriers (NALC), AFL-CIO.
Women and Infants Hospital (01-CA-312111 and 01-CA-312613; JD-19-25) Providence, RI. Administrative Law Judge Renée D. McKinney issued her decision on March 4, 2025. Charges filed by New England Health Care Employees Union, District 1199, SEIU.
***
To have the NLRB’s Weekly Summary of Cases delivered to your inbox each week, please subscribe here.