Republicans Threaten NLRB After Boeing Decision

By: David Dayen

Wednesday May 11, 2011 8:35 am

http://news.firedoglake.com/2011/05/11/republicans-threaten-nlrb-after-boeing-decision/


The Boeing/NLRB dispute, which concerns a second jet
production line Boeing wants to move from unionized
factories in Washington state to right-to-work state
South Carolina, and a labor board injunction against
that, has brought in members of Congress on both sides
as well as interest groups. Rand Paul summarized the
argument of the far right by hinting at a White House
enemies list:

Speaking at the U.S. Chamber of Commerce, South Carolina
Gov. Nikki Haley (R) and several GOP lawmakers -- such as
Sens. Lamar Alexander (Tenn.), Jim DeMint (S.C.),
Lindsey Graham (S.C.) and Rand Paul (Ky.) and Rep. Joe
Wilson (S.C.) -- took turns criticizing the Obama
administration for the complaint.

"This is an issue that may have started in South
Carolina, but we want to make sure it never touches
another state," Haley said. "We are demanding that the
president respond to what the NLRB has done. This goes
against everything we know our American economy to be."
[...]

Other senators pinned the blame on the president for the
labor board's complaint.

"He's responsible for this board. He's stocked it with
his people," DeMint said. The South Carolina senator
also called the complaint "thuggery" and "something you
would expect in a Third World country, not in America."

Paul suggested the complaint showed that the White House
had an "enemies list" consisting of GOP-leaning,
right-to-work states.

"Mr. President, do you have an enemies list? Is this
decision based on the fact that South Carolina appears
to be a Republican state, has two Republican senators?
Is this decision based on the fact that South Carolina
is a right-to-work state? Are they on your enemies
list?" Paul said.

This intimidation and assumption of bad faith ought to
be what we come to expect from the far right these days.

Senate Majority Leader Harry Reid defended the decision
by the NLRB in remarks today, and said that Republicans
need to let the independent agency do its job.

The acting general counsel of the NLRB is a man who is
as nonpartisan and independent as the agency he works
for. Last month, he issued a complaint against one of
America's largest companies, Boeing. The complaint
alleges that after Boeing workers in some states went on
strike, the company retaliated by opening a new
production line in a non-union facility. That kind of
retaliation, if that's what happened, is illegal.

That's just the background. I'm not here to judge the
merits of the case. In fact, I'm here to do the exact
opposite: to remind the Senate that prejudging the case
is not our job. That would overstep long-established
boundaries and weaken our system of checks and balances.

I strongly encourage all of them to take a step back. We
all know Republicans dislike organized labor. We know
they disdain unions because unions demand fairness and
equality from the big businesses Republicans so often
shield at all costs.

Republicans are mad simply because an independent agency
is doing its job. This is deeply concerning to those who
don't want to see government work.

For their part, the NLRB has refused to be intimidated
by Republican threats. Acting general counsel Lafe
Solomon said in a statement that lawmakers should
"respect the legal process, rather than trying to
litigate this case in the media and public arena." An
administrative law judge will rule on the case in June,
and they will have the knowledge in their hands that
Boeing executives actually said out loud that they moved
production lines because of strikes in Washington state.
The judge can determine whether that violates the
federal protection of the right to strike, but if you
asked me my opinion, I'd say it's a slam-dunk case.

But Republicans are doing more than offering their
opinion. They're threatening the livelihoods of the
decision-makers in the case. This only differs from the
US Attorney scandal in that Republicans don't hold the
White House, so the threats are coming from a different
part of the government.

So far, this has been a sequence of charges and
counter-charges. We'll see if the law is allowed to
rule, or if the Obama Administration gets cold feet and
tells the NLRB to call the whole thing off. The NLRB is
an independent agency and wouldn't necessarily have to
listen, but the implication will be clear. A lot of
people are watching this one to see where the White
House will stand.



Boeing Complaint Fact Sheet

http://nlrb.gov/print/443

On April 20, 2011, the Acting General Counsel of the
National Labor Relations Board issued a complaint
against the Boeing Company alleging that it violated
federal labor law by deciding to transfer a second
airplane production line from a union facility in the
state of Washington to a non-union facility in South
Carolina for discriminatory reasons. A hearing has been
set for June 14, 2011 in Seattle before an
administrative law judge.

Click here to see a news release [1]about the complaint,
and here to see a copy of the full complaint [2].

Click here to view Boeing's response to the complaint
[3].


The Charge and Complaint

On March 26, 2010, the International Association of
Machinists and Aerospace Workers, District Lodge 751,
filed a charge with the NLRB alleging that the Boeing
Company had engaged in multiple unfair labor practices
related to its decision to place a second production
line for the 787 Dreamliner airplane in a non-union
facility.

Specifically, the union charged that the decision to
transfer the line was made to retaliate against union
employees for participating in past strikes and to chill
future strike activity, which is protected under the
National Labor Relations Act.

The union also charged that the company violated the
National Labor Relations Act by failing to negotiate
over the decision to transfer the production line. The
Machinists' union has represented Boeing Company
employees in the Puget Sound area of Washington, where
the planes are assembled, since 1936, and in Portland,
Oregon, where some airplane parts are made, since 1975.

Throughout the investigation of the charge, NLRB
officials met with both parties in efforts to facilitate
a settlement agreement. The overwhelming majority of
NLRB charges found to have merit are settled by
agreement. Although no settlement was reached and the
Agency was compelled to pursue litigation, the Acting
General Counsel remains open to a resolution between the
parties.

The complaint issued by the Acting General Counsel
(19-CA-32431 [4]) alleges that Boeing violated two
sections of the National Labor Relations Act by making
coercive statements and threats to employees for
engaging in statutorily protected activities, and by
deciding to place the second line at a non-union
facility, and establish a parts supply program nearby,
in retaliation for past strike activity and to chill
future strike activity by its union employees.

The investigation found that Boeing officials
communicated the unlawful motivation in multiple
statements to employees and the media. For example, a
senior Boeing official said in a videotaped interview
with the Seattle Times newspaper: "The overriding factor
(in transferring the line) was not the business climate.
 And it was not the wages we're paying today.  It was
that we cannot afford to have a work stoppage, you know,
every three years."

The complaint also alleges that Boeing's actions were
"inherently destructive of the rights guaranteed
employees by Section 7 of the Act [5]."

The investigation did not find merit to the union's
charge that Boeing failed to bargain in good faith over
its decision regarding the second line. Although a
decision to locate unit work would typically be a
mandatory subject of bargaining, in this case, the union
had waived its right to bargain on the issue in its
collective bargaining agreement with Boeing.


The Law and Supporting Cases

The NLRB enforces the National Labor Relations Act,
which guarantees employees the right to organize and
collectively bargain, or to refrain from doing so.
Applicable Sections of the Act follow:

RIGHTS OF EMPLOYEES

Section 7 [5]: Employees shall have the right to
self-organization, to form, join, or assist labor
organizations, to bargain collectively through
representatives of their own choosing, and to engage in
other concerted activities for the purpose of collective
bargaining or other mutual aid or protection, and shall
also have the right to refrain from any or all such
activities...

RIGHT TO STRIKE

Section 13 [6]: Nothing in this Act ... shall be construed
so as either to interfere with or impede or diminish in
any way the right to strike or to affect the limitations
or qualifications on that right.

UNFAIR LABOR PRACTICES (relevant sections)

Section 8(a) [7]It shall be an unfair labor practice for
an employer-- (1) to interfere with, restrain, or coerce
employees in the exercise of the rights guaranteed in
section 7; (3) by discrimination in regard to hire or
tenure of employment or any term or condition of
employment to encourage or discourage membership in any
labor organization

Cases:

On the 8(a)(1) charge:

The U.S. Supreme Court delineated the line between
protected employer speech versus unlawful employer
speech under the NLRA in NLRB v. Gissel Packing Corp.,
395 US 575, 618 (1969). [8]

In General Electric Company, 215 NLRB 520 (1974) [9],
the National Labor Relations Board applied the Gissel
test to set aside an election because the employer,
citing concerns about possible future strikes, stated
that the plant's nonunion status was a primary factor in
choosing to locate a production line for a new motor
there. In its decision, the Board distinguished an
employer's right to take defensive action when
threatened with an imminent strike from threats to
transfer work "merely because of the possibility of a
strike at some speculative future date."

Since then, the Board has repeatedly held that an
employer violates section 8(a)(1) by threatening that
employees will lose their jobs if they join a strike, or
by predicting a loss of business and jobs because of
unionization or strike disruptions without any factual
basis. In contrast, the Board has found that employers
may lawfully relate concerns raised by customers
(Curwood, Inc., 339 NLRB 1137 (2003) [10]. They may also
reference the possibility that unionization, including
strikes, might harm relationships with consumers, as
opposed to predicting  "unavoidable consequences."Miller
Industries Towing Equipment, Inc., 342 NLRB 1074,
1075-76 (2004) [11]

On the 8(a)(3) charge:

An employer's discouragement of its employees'
participation in a legitimate strike constitutes
discouragement of union membership within the meaning of
this section. This applies to employer conduct designed
to retaliate against employees for having engaged in a
strike in the past (Capehorn Industry, 336 NLRB 364
(2001) [12]where the employer failed to reinstate
strikers when there was no legitimate business
justification for permanently subcontracting the work),
as well as employer conduct designed to forestall
employees from exercising their right to strike in the
future (Century Air Freight, 284 NLRB 730 (1987)
[13]where employer permanently subcontracted unit work
and discharged employees in order to forestall the
exercise of their right to strike; and Westpac Electric,
321 NLRB 1322 (1996) [14], where employer isolated
employee in retaliation for previous and anticipated
future strike activities). In National Fabricators [1]
295 NLRB 1095 (1989), where potential strikers were
targeted for layoffs, the Board held that "disfavoring
employees who were likely to strike, is the kind of
coercive discrimination that...discourages...protected
activity."


Next Steps

It is important to note that the complaint states
allegations by the Acting General Counsel that the
employer has committed unfair labor practices. The Board
has made no findings on these allegations.  The next
step in the process will be a hearing before an NLRB
administrative law judge, scheduled for June 14 at the
NLRB's Seattle office [15]. At the hearing, both parties
will have an opportunity to present evidence and argue
in favor of their position. The decision of the judge
may be appealed to the Board in Washington by the filing
of exceptions by either party. The Board's decision
could further be appealed to a federal court of appeals
and then to the U. S. Supreme Court.  Click here for a
flow chart of the NLRB process. [16]

This fact sheet was posted on 4/20/2011 and will be
updated periodically. Source URL:
http://nlrb.gov/node/443

Links: [1]
http://nlrb.gov/news/national-labor-relations-board-
issues-complaint-against-boeing-company-unlawfully-
transferring- [2]
http://nlrb.gov/sites/default/files/documents/443/cpt_19
-ca-032431_boeing__4-20-2011_complaint_and_not_hrg.pdf
[3]
http://nlrb.gov/sites/default/files/documents/443/
boeing_answer_final_19-ca-032431_2.pdf [4]
http://nlrb.gov/category/case-number/19-ca-032431 [5]
http://nlrb.gov/national-labor-relations-act#7 [6]
http://nlrb.gov/national-labor-relations-act#13 [7]
http://nlrb.gov/national-labor-relations-act#8a [8]
http://supreme.justia.com/us/395/575/case.html [9]
http://mynlrb.nlrb.gov/link/document.aspx/
09031d45800aef2c [10]
http://mynlrb.nlrb.gov/link/document.aspx/
09031d45800c0fe6 [11]
http://mynlrb.nlrb.gov/link/document.aspx/
09031d45800076da [12]
http://mynlrb.nlrb.gov/link/document.aspx/
09031d45800c0dcf [13]
http://mynlrb.nlrb.gov/link/document.aspx/
09031d45801b3331 [14]
http://mynlrb.nlrb.gov/link/document.aspx/
09031d45800ba34b [15]
http://nlrb.gov/category/regions/region-19 [16]
http://nlrb.gov/nlrb-process
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