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National Labor Relations Board v. Transportation Management Corp.
United States Supreme Court
462 U.S. 393 (1983)
Sam Santillo (plaintiff) was a bus driver for Transportation Management Corp. (TMC) (defendant). Santillo tried to organize several other bus drivers to join a union with him. Santillo’s supervisor, George Patterson, learned of Santillo’s union activity. Patterson told other drivers that he would “get even” with Santillo and that he was taking Santillo’s actions “personally.” A few days later, Patterson fired Santillo for the asserted reasons that Santillo (1) left his keys in the bus and (2) took unauthorized breaks for coffee and at home. This conduct was common among the bus drivers and tolerated if it did not interfere with their duties, Santillo did not receive any warning prior to his discharge, and TMC had never fired an employee before for the same conduct. Santillo complained of his discharge to the National Labor Relations Board (the board). The general counsel filed a complaint, and the administrative law judge (ALJ) ruled in Santillo’s favor. The ALJ found that Patterson was motivated by antiunion animus in discharging Santillo and that TMC’s asserted reasons for discharge were pretextual. The board affirmed, applying the applicable legal standard. The Court of Appeals for the First Circuit denied enforcement of the board’s order based on the court’s belief that the general counsel was required to prove that Santillo would not have been fired had it not been for his union activities. The Supreme Court reviewed the matter.
Rule of Law
Holding and Reasoning (White, J.)
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