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American Steel Construction, Inc.

372 N.L.R.B. No. 23 (2022)

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American Steel Construction, Inc.

National Labor Relations Board
372 N.L.R.B. No. 23 (2022)

SC

Facts

Local 25, International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers, AFL-CIO (Local 25) (plaintiff) filed a petition at the National Labor Relations Board (NLRB) seeking to represent in collective bargaining a unit of all journeymen and apprentice field ironworkers at American Steel Construction, Inc. (American Steel) (defendant). American Steel objected to the petition and argued that the unit was not appropriate for collective bargaining without also containing the company’s painters, drivers, and fabricators. In 2017, in PCC Structurals, Inc., the NLRB had overruled Specialty Healthcare & Rehabilitation Center of Mobile, which had set the prevailing standard for unit-determination cases. Applying PCC Structurals, the NLRB regional director ruled in American Steel’s favor, finding that the company’s field ironworkers did not have a community of interest that was sufficiently different from the company’s other workers. Local 25 appealed the decision to the full NLRB.

Rule of Law

Issue

Holding and Reasoning ()

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