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General Electric Co. v. National Labor Relations Board

United States Court of Appeals for the Second Circuit
412 P.2d 512 (1969)


In 1966, more than 80 unions represented workers at General Electric Co. (GE) (defendant). The International Union of Electrical, Radio, and Machine Workers (IUE) represented about 80,000 of them. The IUE formed a collective-bargaining committee (CCB) with seven other unions that represented GE workers, to increase its bargaining power. The existing contract between GE and the IUE required them to begin formally negotiating a new contract in August 1966. Three months beforehand, the CCB tried to persuade GE representatives to meet for preliminary discussions, but GE refused to bargain with the eight-union coalition. The IUE then added seven members to its negotiating committee, one from each of the other unions. When GE representatives appeared for a meeting and saw the other union members, GE refused to negotiate. The IUE explained that the new members were not voting members and served only to aid negotiations and that the IUE did not try to bargain on behalf of other union’s workers, but GE still refused to talk. The IUE filed charges alleging that GE wrongfully refused to bargain in violation of the National Labor Relations Act. The National Labor Relations Board found a mixed-union bargaining group not necessarily improper absent bad faith or improper motive, making refusal to bargain with the group an unfair labor practice. GE appealed.

Rule of Law


Holding and Reasoning (Feinberg, J.)

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