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Milwaukee Spring Division of Illinois Coil Spring Co.

National Labor Relations Board
268 N.L.R.B. 601 (1984)


During the term of a collective-bargaining agreement (CBA) with the United Auto Workers (UAW) (plaintiff), the Milwaukee Spring Division of Illinois Coil Spring Company (defendant) moved assembly operations from its unionized facility in Milwaukee to a nonunionized facility in McHenry, Wisconsin. Beforehand, the company told UAW that its wage rates necessitated the move and asked it to concede a scheduled wage increase, but UAW refused. The company also proposed several alternatives to relocation, but UAW rejected them and declined to bargain further. The company moved assembly operations and laid off Milwaukee workers. The union filed charges against the company with the National Labor Relations Board (NLRB). The NLRB found the relocation violated the CBA even though it did not contain a work-preservation provision that required keeping jobs in Milwaukee. Both sides appealed. After President Reagan appointed new members to the NLRB, the appellate court remanded for additional consideration.

Rule of Law


Holding and Reasoning

Dissent (Zimmerman, Member)

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