Electromation, Inc. v. National Labor Relations Board
United States Court of Appeals for the Seventh Circuit
35 F.3d 1148 (1994)
- Written by Rose VanHofwegen, JD
Facts
Electrical-component manufacturer Electromation, Inc. (defendant) had about 200 employees. When Electromation changed its attendance-bonus and wage policies, 68 dissatisfied employees signed a letter requesting reconsideration. Electromation created action committees to address five subjects, including the attendance-bonus policy but not wages, and posted sign-up sheets. Employees initially resisted, but management pressed the idea until they accepted. Electromation decided each committee would comprise five employees, a manager or supervisor, and employee-benefits manager Laura Dickey, who set committee agendas and coordinated meetings. Employees could serve on only one committee at a time. Electromation paid employees for time spent in meetings and provided a conference room and supplies. The attendance-bonus committee developed one proposal that was rejected as too costly. Otherwise, no action had been taken when the International Brotherhood of Teamsters petitioned the National Labor Relations Board (NLRB) (collectively, plaintiffs) for union recognition. Electromation said the committees could continue meeting without management representatives present, but the committees disbanded. The NLRB found the committees were labor organizations under the National Labor Relations Act (NLRA) and that Electromation had engaged in unfair labor practices by creating and dominating the committees. Electromation appealed.
Rule of Law
Issue
Holding and Reasoning (Will, J.)
What to do next…
Here's why 814,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.