The Federal Labor Relations Authority (FLRA) has a similar mandate to the NLRB. The Authority has held on a number of occasions that after an agency has unilaterally implemented changes in conditions of employment, subsequent offers to bargain over the changes do not cure the statutory violation, and post-implementation actions are irrelevant. There are five people in total on the NLRBs board. Since the Union had been actively pursuing mediation, the Union team understood this to mean that the Agency was refusing to engage in mediation. Jones testified that his team tried to find areas where we could compromise[,] but he acknowledged that they did not provide specific counterproposals for each Union proposal. cubicles. 32-33. Prior to this swing move occurring, the Agency and the Union engaged in formal negotiations and executed a Memorandum of Agreement on the subject on December11. But the ULP also involved, and was of concern to, the Unions members outside the Washington, D.C., area, as the bargaining units are nationwide in scope and many of the Union negotiators worked outside Washington. . GC Ex. 12. In order to evaluate this defense, I consider the meaning of the ground rules agreement, using the standards and principles of interpreting agreements applied by arbitrators and the federal courts. The FLRA is an independent administrative federal agency that administers the labor-management relations program for 2.1million non-postal federal employees worldwide. Dec. 4, 1987), NLRB Union v. Federal Labor Relations Authority, 834 F.2d 191, 1987 U.S. App. 113. Donna Nixon was scheduled to be on a flight that night. The NLRB administers and enforces the National Labor Relations Act, conducting secret ballot elections to determine whether employees wish to be represented by a union, and resolving alleged ULPs committed by employers and unions in the private sector. Durkin (along with Nixon and later Luther) responded, [N]o, the Agency has to continue bargaining. . 12; Tr. Was NLRB barred by the statute of limitations? 14 at 3. Organized labor is a strategy where workers join together in unions in order to negotiate for better wages and working conditions. The U.S. Court of Appeals for the D.C. Tr. The FLRAis the federal public sector counterpart to the National Labor Relations Board (NLRB), which governs labor relations between private sector employees and employers. The reason that knowing the distinction between employment laws and labor laws is important, especially when hiring an attorney, is because lawyers who claim to be both labor and employment lawyers have a tendency to specialize in one and dabble in the other. 32, 264. Annual Subscription ($175 / Year). 29 at 1. some of the areas [of] discussions that we had with the Union, such as the Unions suggestion to have a second nursing room. was to see where there was common ground, to see what we could agree on. GC Ex. Luther also provided Jones with proposed ground rules for the negotiations. Each has its own procedures and rules that if an attorney does not know could result catastrophic error. 431. Ithink the idea was we would exchange . 428. Also on April 14, an architect at WDG provided Jones with updated drawings for Half Street. 47 at 1. The Union told Jones that there were a number of ways to bargain. GC Ex. The Union asked to submit its remaining counterproposals the following week, and to resume bargaining thereafter, since it had not had time to prepare a response on all issues. Theres a lot of technology out there that you can use for that sort of thing. Tr. Asked to explain why the Union team did not stay, Durkin stated: [W]e couldnt continue that evening. David M. Prouty. 470. The Unions two other counterproposals were very similar to Agency proposals, indicating that further discussions could have led to an agreement. Impact of the NLRB on Professional Sports., The New York Times. Half Street. The Union team consisted of Julia Durkin, an attorney at the Agencys Denver Regional Office, who served as a local president and had bargained over an office move in Denver (Tr. at 12. The 60 day period for seeking judicial review set forth in the Hobbs Act is jurisdictional in nature, and may not be enlarged or altered by the courts. 104. On January 31, the Union informed the Agency that it had assembled a team to bargain over the move. The National Labor Relations Board is an independent federal agency vested with the power to safeguard employees' rights to organize and to determine whether to have unions as their bargaining representative. This rapprochement should have. This argument ignores the important difference between the text of the NLRA and the text of the FSLMRS. 237. 34. 233-34. Issued, Washington, D.C., February 11, 2016, Date: _________________ By: _______________________________________________, Chairman, National Labor Relations Board (Signature), Date: _________________ By: ______________________________________________, General Counsel, National Labor Relations Board (Signature), Collaboration and Alternative Dispute Resolution Office (CADRO), Archival Decisions, Legislative History, & Foreign Service Decisions, NATIONAL LABOR RELATIONS BOARD AND NATIONAL LABOR RELATIONS BOARD UNION. The three members cannot be from the same political party. We dont intend to waste our time, and that of a mediator, to engage in a useless undertaking.. That AFSCME will publicize how the current NLRB and FLRA are enforcing our federal labor laws to hinder, rather than promote, collective bargaining. Therefore the union can usually rest in at least a legal assurance that, whenever the agency notifies it of a proposed change and gives it the opportunity to bargain, its opportunity will be adequate. Tr. When asked at the hearing whether the Agency had made decisions with regard to furniture at the time of the April negotiations, Jones said, No. Tr. With regard to Proposal 14 that interior office windows have an opaque glaze or frosted glass Jones said, we havent chosen yet to frost or not frost, but we want it to be uniform, so we cant have individual people in individual offices choosing whether to have theirs frosted or not. Tr. Learn more about federal labor-management relations, including unfair labor practices, representation matters, impasses, and negotiability. Timing and Availability of Judicial Review, The Constitution and the Administrative State, Statutory Constraints on Agency Procedure, Constitutional Constraints on Agency Procedure, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam). The General Counsel claims that the Agency was required to bargain until either an agreement or impasse was reached, citing. The obligation to bargain over a relocation arises when a lease is signed (if not earlier) and the union requests to bargain. Tr. 96-97. According to Durkin, Sutton stated that the project was running behind schedule in design plans; at a later phase of the process, after construction drawings were made, theyd decide on furniture. Tr. Where they mainly differ is in the portion of the workforce they serve. Jones, by contrast, testified that the parties reached impasse on April 24, [w]hen the Union got up and walked out. Tr. [on] the 24th, we walked through each of these and there was some general discussion. . Tr. Over the weekend of December 13 and 14, the Agency needed to vacate a portion of its office space at Franklin Court to enable the new tenants to move in; this required employees in the vacated space to move into the remaining Agency space at Franklin Court. . On February 5, Luther emailed Jones the Unions request to bargain over the relocation. Meanwhile, Nixon and Luther pressed Jones about their need to obtain the drawings and review them in advance of negotiations, and about the Agencys failure to respond to the Unions proposed ground rules. 375. 85-88; GC Ex. there has to be an end point. The National Labor Relations Board (NLRB) is an independent federal agency created by the U.S. Congress in 1935 to enforce the National Labor Relations Act (NLRA)a landmark piece of legislation designed to protect the rights of most private-sector employees to collectively bargain for better wages and working conditions with or without the help of a labor union. The next day, May 7, most of the Union team participated in a videoconference with NLRB General Counsel Griffin and Rachel Lennie, which focused primarily on the Unions pending information requests and its need to have this information in order to bargain properly. During its negotiations with the Union in April, Agency negotiators told the Union team that all issues relating to the relocation had to be negotiated and finalized before the May 9 deadline given to them by GSA. The NLRB My Account Portal is an NLRB website that allows individuals to view cases and inquiries to which they are a party, e-file documents in those cases/inquiries, view their e-file history and manage their user profile. . If the Union had had the opportunity to argue for its proposals in February or March, it might have been able to persuade management, the architects, and GSA that the Agency needed an additional 10,000 or 12,000 square feet, rather than 8,000. 90-91. 18, 19. 30. Woodcock testified that Griffin started out by discussing . . Jones replied that same day, conceding that the process has fallen slightly behind schedule.. On May 16, Jones provided an additional response to the May 6 information request, forwarding to the Union a variety of drawings for Half Street, including some dated March 26 (GC Ex. First, the Agency had already made the decision, with GSA, to utilize GSAs FIT program, which significantly narrowed the remaining options for furniture. Jones did not articulate his understanding of paragraph 2 to the Union team until substantive negotiations had begun on April 23, and the Union immediately disputed his understanding. As for whether the parties had reached impasse by the end of the April 23-24 bargaining session, Durkin stated that they had not, noting that neither party submitted last best offers or asserted they were at impasse. In setting forth the distinction, Ill start with labor laws because they represent a much narrower area of law than employment laws. In sum, the parties could have engaged in productive discussions over the Unions proposals after April 24. She also asked for any and all documents showing, for each bargaining unit employee as of July 1, 2013, the square footage, whether by office, workstation, by cubicle or by work area allocated to each particular employee, among other things. . to negotiate before a firm decision had been made to relocate.. Monday, January 13, 2020. The National Labor Relations Board is a federal agency that enforces the National Labor Relations Act. In its opening statement at the hearing, Respondents counsel similarly asserted that it had no further bargaining obligations regarding the relocation after it bargained on April 23 and 24. Protecting rights and facilitating stable relationships among federal agencies, labor organizations, and employees while advancing an effective and efficient government through the administration of the Federal Service Labor-Management Relations Statute. Find historical decisions ofthe Assistant Secretary of Labor for Labor-Management Relations and the Federal Labor Relations Council, as well as Foreign Service Labor Relations Board decisions. Dissent. 7101-7135. WE WILL NOT, in any like or related manner, interfere with, restrain, or coerce bargaining unit employees in the exercise of the rights assured them by the Statute. Asked to describe this portion of bargaining, Luther testified that there were a number of proposals during the course of the day where the Agencys response was, well, we dont know; we dont know about the furniture [Proposal 36]; we dont know about film on the glass [Proposal 14]; we dont know about coat hooks [Proposal 28]; we dont know about these things yet, which would indicate at some point, there would need to be further discussion about them . . . . 39. But since this is the agencys problem and not the unions, the union often has only a more or less passive interest in how the agency arranges to fulfill its obligation as long as it does fulfill it. Were moving. NLRB, the National Labor Relations Board, is an independent federal agency vested with the ability to safeguard employees' rights to organize and to determine whether to have unions as their bargaining representative. About two hours later, the Union team submitted five of its own counterproposals, which the Agency rejected. Ex. The Agency denied the request, insisting that the ground rules limited bargaining to two days. the background and history of the move, and talked about it being a very tight timeline, tight monetary restrictions. Tr. You can find out more about our use, change your default settings, and withdraw your consent at any time with effect for the future by visiting Cookies Settings, which can also be found in the footer of the site. 115. GC Ex. . GC Exs. 100-01, 230-31. Understanding the National Labor Relations Board (NLRB), National Labor Relations Board (NLRB) Responsibilities, National Labor Relations Board (NLRB) Structure, Examples of the National Labor Relations Board (NLRB) Defending Employee Rights. 166. Graham indicated that this decision didnt need to be made until the move-in date, prompting Durkin to argue, this is why we need to continue bargaining after today. Ch. As we said several times throughout the course of the day, we were willing to work late last evening in an attempt to reach an agreement, or narrow the issues, but the Union team was unwilling to continue beyond 6:30. In this regard, the GC asserts that there was no clear and unmistakable waiver of the Unions right to bargain to agreement or impasse. The Union declined to stay beyond 6:30 p.m., and the Agency declared that negotiations were terminated. 22. 33, 42-43, 403; GC Ex. As part of this process, the Agency established the Space Advisory Committee around November 2012. Jones asked Durkin and Luther not to, saying, You agreed to a visual inspection and thats what we expect this to be. Tr. Tr. While denying that it had floor plans of the existing offices, the Agency prevented Union officials from taking. As an attorney, I am often asked what the difference is between employment law and labor law. It also helps employees conduct union elections. things that we could agree on. Tr. In this vein, the Agency continued to submit changes to the design drawings to GSA and to make decisions about furniture options (most significantly, adopting GSAs FIT program, which drastically limited the remaining furniture choices), window and glass treatments, lighting, and cubicle height. 105. . The agency also acts to prevent and remedy unfair labor practices committed by private sector employers and unions. On Wednesday, April 23, the Unions bargaining team met with Agency representatives Jones and Graham. [5] In August 2021, President Biden nominated eight-year assistant general counsel Kurt Rumsfeld to the position.[6]. According to Luther, Sutton also said that there had been a great deal of work with [various Agency officials] . Br. On April 3, Jones told the Union, with regard to a walk-through of Franklin Court, that people will be working and cannot be disturbed, so you should not plan on measuring/inspecting individual employee workspace or conversing with employees during duty time. GC Ex. 409; This evidence shows that there was a significant period of time prior to April 14 in which the Agency was able to make meaningful changes in the size and configuration of the office space at Half Street. Effective Friday July 31, 2020, the agency now extends the prohibition on in-person filings indefinitely. Many of these proposals were not related to the size of individual offices or cubicles, and indeed the Agency itself had no way of properly or knowledgeably negotiating many of these subjects (such as the height of cubicle walls, frosting on glass, and options for furniture, flooring, and walls) in April or May. Clearly, the Respondents national office was involved in this ULP, which involved negotiations over the relocation of its national headquarters. . 29 at 3-4. My reaction to this was that we rejected this because it wasnt a comprehensive proposal. The NLRA, otherwise known as the Wagner Act, is one of the most groundbreaking labor laws ever enacted in the United States. Jt. . About 450 people work at its headquarters office in Washington, D.C. Tr. . Featherbedding describes an unlawful practice of forcing employers to increase labor costs, such as hiring unnecessary workers. informed the Union that the Respondent had fulfilled its obligation to bargain over the effects of the Headquarters Office Move, and that [s]ince on or about May15, 2014, the Respondent has failed and refused to negotiate with the Union over the Headquarters Office Move to the extent required by the Statute, in violation of 7116(a)(1) and (5) of the Statute. . He indicated that at that point in the process, major changes, such as adding movable walls or more bathroom stalls, would be difficult, if not impossible. The agencys board is also not permitted to act on its own motion and can only pursue cases that have been initiated by employees, employers, or unions. The FLRA is an independent administrative federal agency created by Title VII of the Civil Service Reform Act of 1978, also known as the Federal Service Labor-Management Relations Statute (the Statute ), 5 U.S.C. Well meet today and tomorrow [April 23-24], and thats it. Tr. 6. The Agencys proposed interpretation of the ground rules also ignores paragraph 13, which states that either party may request mediation from the Federal Mediation and Conciliation Service (FMCS). Mutual consent is not required for mediation. 5. It makes no sense for the Agency to use the ground rules to declare that bargaining was over, when those very ground rules enabled either party to initiate mediation. . . Jt. GC Ex. Durkin reiterated that the Union disagreed with that position. However, Lennie indicated that the Agency would look into seeing whether they could find additional space for more stalls. Synopsis of Rule of Law. Notwithstanding the lack of drawings, Jones and Durkin began on March 12 to discuss ground rules and potential dates for negotiations. 39. The Union offered to submit a counterproposal on the remaining issues by April 30, and it requested that bargaining continue, using all technological means at the parties disposal, including telephone and videoconferences, in addition to face-to-face meetings. The Board has five Members and primarily acts as a quasi-judicial body in deciding cases on the basis of formal records in administrative proceedings. Although the Agencys counterproposals didnt address this issue, and the Agencys existing floor plans contained no details about furniture, Jones testified that this could have been negotiated on April 24, and the Agency would have entertained Union furniture proposals on April 24, if the Union had demanded specific types of desks or chairs. GC Ex. The FLRA was adopted after President Jimmy Carter sought legislation to bring comprehensive reform to civil service system and regularize federal labor relations. and it didnt fit. Tr. When the parties began face-to-face negotiations on April 23, they had signed off on the ground rules less than a week earlier. . 24. that the Agency had had the drawings for a month at that point in time. Tr. If mediation assistance takes place, but no agreement is reached, either party may thereafter request assistance from the Federal Service Impasses Panel. 9; Resp. Accordingly, the Union will submit a proposal and/or counterproposal to the Agencys 4/24/14 counterproposal on April 30, 2014. Iagree with the Union that this was not sufficient time for the Union to respond fully to the Agencys counterproposals. Mediation is, without a doubt, a form of bargaining. It was during this period of time that the Union could have been afforded a similar opportunity to add its perspective and interests into the discussion that was going on between the Agency and the architects. Durkin replied that we anticipate continuing bargaining, and that the Union was focusing here now on time sensitive issues like the size of offices, but we anticipate bargaining over these things into the future. Tr. Tr. - Legal Principles in this Case for Law Students. 288), and Graham and Jones both acknowledged that no agreement was reached. And at that time, at 6:30, the Agency had already rejected its own proposals. Find everything you need to know about filing a casewith the FLRA. at 330. 233), and officials of both unions asked that they be given copies of the exercises that had been done, so that the unions could evaluate the feasibility of different alternatives. . If the parties had truly intended to establish a fixed time period for the negotiation of all issues related to the Agencys relocation, it could have done so, simply by stating that April 24 would be the last day for bargaining and by further specifying a fixed period for engaging in mediation and invoking FSIP assistance. GC Ex. Ex. Failing to do so can lead to unfavorable outcomes. 108. Around this time, an architecture firm, WDG, was selected to design the interior space at Half Street. , Tr. When asked why the Agency rejected the five counterproposals offered by the Union late on April 24, Jones stated, [W]e were too early on. 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