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National Labor Relations Board, United Food & Commercial Workers, Local 204, Afl-Cio International Union of Operating Engineers, Local 465, Afl-Cio, Intervenors v. Lundy Packing Company, in Re Lundy Packing Company, Incorporated

Citations: 81 F.3d 25; 151 L.R.R.M. (BNA) 3050; 1996 U.S. App. LEXIS 5570Docket: 96-1177

Court: Court of Appeals for the Fourth Circuit; February 14, 1996; Federal Appellate Court

Narrative Opinion Summary

The case before the United States Court of Appeals for the Fourth Circuit involved a challenge to the National Labor Relations Board's (NLRB) determination regarding a bargaining unit for Lundy Packing Company. The court was tasked with deciding whether to enforce the NLRB's bargaining order. The primary legal issue centered on the jurisdiction transfer outlined in Section 10(e) of the National Labor Relations Act, which provides that jurisdiction moves to the court upon the filing of the record, preventing the NLRB from revisiting or making new rulings on the case. Lundy's refusal to bargain was intended to bring the representation proceedings before the court for review, but no unfair labor practice finding was established, which is typically required for such a review. The court held that the NLRB overstepped its jurisdiction by attempting to revive the representation petition. Consequently, the court denied the NLRB's request to enforce its order and closed the case, while granting the unions' motion to intervene and denying Lundy's motions for a stay and a writ of mandamus. The decision was delivered with concurrence from the panel of judges, including Chief Judge Wilkinson and Judges Niemeyer and Hamilton.

Legal Issues Addressed

Authority of NLRB Post-Jurisdiction Shift

Application: The court found that the NLRB's attempt to revive the representation petition exceeded its jurisdiction after the court had taken over the case.

Reasoning: The NLRB's attempt to revive the representation petition following the court's decision exceeded its jurisdiction.

Jurisdiction under Section 10(e) of the National Labor Relations Act

Application: The court emphasized that once the record is filed, exclusive jurisdiction is granted to the reviewing court, preventing the NLRB from reopening or making additional rulings.

Reasoning: The court did not remand the case for further proceedings, emphasizing that once exclusive jurisdiction is granted to the reviewing court, the NLRB cannot reopen or make additional rulings.

Review of Representation Proceedings

Application: The court noted that representation proceedings are reviewed in the context of an unfair labor practice finding, which was not established in this case.

Reasoning: Review of representation proceedings typically occurs only in the context of an unfair labor practice finding, which was not established in this case.