Dodge of Naperville v. NLRB, No. 12-1032 (D.C. Cir. 2015)
Annotate this CaseThe company appealed the Board's finding that the company had committed various unfair labor practices during the relocation of union employees from a dealership that was closing down to a larger dealership with non-union employees. The Board concluded that the company acted unlawfully when it withdrew recognition of the Union. The company argued that it had no choice but to withdraw recognition of the Union, on the ground that the relocated employees had been absorbed into a larger unit of non-union employees at the new dealership. The court rejected the company's arguments and concluded that it was required to bargain with the Union about the former employees' initial wages, benefits, schedules, and other terms and conditions. During such bargaining, the employer was required to consider “any proposals” put forth by the Union on these topics. The court upheld as reasonable the Board’s conclusion that the company unlawfully withdrew recognition of the Union when it did so immediately upon the relocation, prior to any effects bargaining. The court rejected the company's challenge to the composition of the Board itself. Accordingly, the court denied the company's petition for review and granted the Board's cross-application for enforcement.
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