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Seattle Seahawks v. NFLPA & Sam McCullum

National Labor Relations Board
292 N.L.R.B. 110 (1989)


For five years, Sam McCullum (defendant) was a starting wide receiver for the National Football League’s (NFL) Seattle Seahawks (plaintiff). In 1981, McCullum was chosen by his teammates to be their union representative. McCullum’s union activities caused tension with the Seahawk’s coach, Jack Patera. Specifically, Patera was upset with McCullum’s organizing a “solidarity handshake” with players from the Seahawks and players from the opposing team before the first pre-season game. Additionally, McCullum remarked at a press conference that Seahawks team doctors released injured players for games too soon when they had not fully recovered. At the end of training camp, the Seahawks obtained another wide receiver, Roger Carr, and cut McCullum from the team. McCullum and the National Football League Players Association (NFLPA) (defendant) filed an unfair labor practice claim with the National Labor Relations Board (NLRB). At trial, the administrative law judge (ALJ) found the Seahawk’s decision to cut McCullum was influenced by Patera’s anti-union sentiments directed at McCullum. The Seahawk’s appealed the decision to the NLRB.

Rule of Law


Holding and Reasoning (Board.)

Dissent (Johansen, Member.)

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