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Grinnell Fire Protection Systems Company v. National Labor Relations Board, Grinnell Fire Protection Systems Company v. National Labor Relations Board
Citations: 272 F.3d 1028; 168 L.R.R.M. (BNA) 2976; 2001 U.S. App. LEXIS 25961Docket: 00-4044, 01-1339
Court: Court of Appeals for the Eighth Circuit; December 5, 2001; Federal Appellate Court
The case involves Grinnell Fire Protection Systems Company and the National Labor Relations Board (NLRB) regarding the Road Sprinkler Fitters Union, Local 669. Following the expiration of their collective bargaining agreement in 1994, the Union went on strike, while Grinnell continued operations with nonstriking employees and replacement workers. The Union filed unfair labor practice charges when Grinnell refused to provide names and home addresses of employees in the bargaining unit after supplying payroll information. An administrative law judge (ALJ) ruled that Grinnell's refusal constituted an unfair labor practice, as the requested information was deemed presumptively relevant for the Union's duties. The NLRB upheld the ALJ's decision, ordering Grinnell to disclose the information. Grinnell contested the ruling, and the court reviewed the NLRB's findings for substantial evidence and legal consistency with the National Labor Relations Act. The court reaffirmed that an employer's obligation to bargain in good faith includes providing relevant information to the Union. While the Board generally considers the names and addresses of replacement employees as relevant, such information can be withheld if confidentiality concerns outweigh the Union's need. In this case, the Union's rationale for needing the information—primarily for representation and solicitation—was viewed as insufficient, particularly since replacement employees had been accessible since 1994, allowing the Union ample opportunity to communicate with them. The Union's vice-president testified to having visited work sites and contacted replacement employees previously, indicating that the need for the requested information was not compelling enough to override potential confidentiality concerns. Collective bargaining is currently in progress, but it is unclear if it will affect the employment status of replacement employees. While the names of bargaining unit employees are pertinent to this process, their home addresses are deemed less relevant, as the Union can communicate with employees at work, and employees can provide their home addresses voluntarily. The Union likely possesses many of these addresses from prior interactions. Regarding privacy, employees have a limited interest in keeping their names confidential, as they are generally known in the workplace, but they hold a stronger interest in protecting their home addresses, despite no evidence of threats against them. Consequently, Grinnell is found to have committed an unfair labor practice by refusing to disclose the names of bargaining unit employees, while the refusal to disclose home addresses is justified. The Board's order requiring the disclosure of names is enforced, while the demand for home addresses is denied. Judge Andrew W. Bogue participated in this decision.