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National Labor Relations Board v. Exchange Parts Co.
United States Supreme Court
375 U.S. 405 (1964)
The Boilermakers Union advised Exchange Parts Co. (defendant) that a majority of its employees had supported union representation and petitioned the National Labor Relations Board (NLRB) (plaintiff) for an election. Two weeks before the election, the company sent its employees a letter detailing the benefits the company had provided for over a decade, stating, “The Union can’t put any of those things in your envelope—only the Company can do that. . . . [I]t didn’t take a Union to get any of those things and . . . it won’t take a Union to get additional improvements in the future.” The company included a statement of benefits with a new overtime policy that increased wages during holiday weeks and a better vacation schedule. The union lost the election, but the NLRB found that the letter violated the employees’ right to organize without employer interference under the National Labor Relations Act (NLRA). The circuit court of appeals reversed, reasoning that the benefits the company offered were permanent and unconditional even though intended to affect the election outcome. The union appealed to the Supreme Court.
Rule of Law
Holding and Reasoning (Harlan, J.)
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