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National Labor Relations Board, and Telecom Plus of New York City, Inc., Intervenor v. Local 3, International Brotherhood of Electrical Workers

Citations: 861 F.2d 44; 129 L.R.R.M. (BNA) 3014; 1988 U.S. App. LEXIS 14984Docket: 169

Court: Court of Appeals for the Second Circuit; November 3, 1988; Federal Appellate Court

Narrative Opinion Summary

The case involves Local 3 of the International Brotherhood of Electrical Workers, which engaged in picketing against Telecom Plus after the latter recognized a different labor organization as its bargaining representative. The National Labor Relations Board (NLRB) found that Local 3's actions constituted recognitional or organizational picketing, violating Sections 8(b)(7)(A) and (C) of the National Labor Relations Act. Local 3's reliance on the 'ally doctrine' was dismissed by the NLRB as inapplicable, and its 'single employer' argument was reframed as an 'alter ego' defense and similarly rejected, based on precedents such as Howard Johnson Co. v. Hotel, Restaurant Employees. Given Local 3's history of unfair labor practices, including twenty-three violations of Section 8(b) since 1960, the NLRB issued a broad cease and desist order, emphasizing the need for stricter remedies for repeat offenders. The Board's decision to enforce the order was supported by substantial evidence of Local 3's pattern of unlawful conduct, rendering any contestation of the order's breadth by Local 3 untenable.

Legal Issues Addressed

Ally Doctrine Defense

Application: Local 3's defense based on the ally doctrine was rejected due to its inapplicability in the circumstances of the case.

Reasoning: Local 3's defense based on the 'ally doctrine' was rejected, as the NLRB found it inapplicable in this context.

Alter Ego Defense

Application: The argument presented by Local 3 regarding common ownership was characterized as an alter ego defense and dismissed based on precedent.

Reasoning: Local 3's argument of being a 'single employer' was recharacterized as an 'alter ego' defense and was dismissed despite common ownership between Telecom Plus and another entity involved in a strike.

Broad Cease and Desist Orders for Repeat Offenders

Application: Given Local 3's extensive history of unfair labor practices, a broad cease and desist order was deemed justified by the NLRB.

Reasoning: The NLRB asserts that stricter remedies are warranted for repeat offenders, which applies to Local 3's ongoing violations.

Recognitional or Organizational Picketing under NLRA

Application: Local 3 engaged in picketing that was deemed recognitional or organizational, violating specific provisions of the National Labor Relations Act.

Reasoning: The National Labor Relations Board (NLRB) determined that Local 3's actions constituted recognitional or organizational picketing in violation of Sections 8(b)(7)(A) and (C) of the National Labor Relations Act.