International Union, United Automobile, Aerospace and Agricultural Implement Workers v. National Labor Relations Board

Illinois Coil Spring Company (the company) (defendant) manufactured automobile parts at three divisions, including Milwaukee Spring and McHenry Spring. The International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (the union) (plaintiff) represented Milwaukee Spring employees, while McHenry Spring employees were nonunion. Between 1980 and 1983, the union and the company had a collective-bargaining agreement with provisions covering wages, management rights, and various other subjects. However, there was no provision covering work preservation, i.e., requiring work to be performed at Milwaukee Spring. In 1982, the company asked the union to forgo a scheduled wage increase due to the company’s deteriorated financial condition from a major contract loss. The company indicated that it was considering relocating its Milwaukee Spring assembly operations to McHenry Spring, where labor costs were lower, but the company welcomed the union’s proposals or suggestions. Substantial bargaining ensued, and the union employees voted to reject any contract concessions. Thereafter, the company decided to transfer assembly operations to the McHenry Spring facility. The union initiated an action before the National Labor Relations Board (the board). In the board’s final decision, it dismissed the union’s case, finding that there was no work-preservation clause in the collective-bargaining agreement and the company was not restricted in any way from deciding to relocate its operations. Thus, the board found that the company did not impermissibly modify the collective-bargaining agreement in violation of the act. The union appealed.