Skip to main content

NLRB: Employee’s Verbal Threats May Be Protected Activity Under NLRA


Alle Processing Corp. - NLRB


Facts:  The employer, Alle Processing Corp. (“Alle”), entered into a bargaining relationship with a local union.  The collective bargaining agreement (“CBA”) contained a union security clause which required that all bargaining unit employees become members of the union as well as a clause that the union could request the employer to terminate employees that failed to pay dues and initiation fees.  The CBA included a checkoff clause which enabled the employer to deduct union dues from the paychecks of employees and remit the dues directly to the union.  (The dues deductions were voluntary and each employee was required to voluntarily sign a checkoff authorization form.)

Although union representatives were able to get most employees to sign deduction authorization forms, some employees held out.  The manager at one of Alle’s plants met individually with the employees that held out and eventually only one employee refused to sign the form.  During the first meeting with the employee, he calmly declined to sign.  At the second meeting, after being convinced to sign the form, a comment from Alle’s management caused him to flip off the manager.  The manager immediately threatened to terminate the employee.  The employee responded “I can get to you whenever I want...whenever I want I can find you...this is how I work, I’m a streets guy.”  The employee subsequently grabbed a small carousel containing coffee items, acted as if he would throw it, but was stopped from doing so.  The employee was thereafter terminated and he left the Alle plant without any further incident.

The employee proceeded to file a charge with the National Labor Relations Board (“NLRB”) and Claim Alle violated his Section 8(a)(3) and (1) rights by terminating him for refraining from joining the union and/or declining to sign the checkoff authorization form.  The Administrative Law Judge found that Alle committed an unfair labor practice when it violated the employee’s Section 8(a)(3) and (1) rights under the National Labor Relations Act (“NLRA”) when it terminated they employee for refraining from becoming a member of the union and/or declining to sign the checkoff authorization form.  The full NLRB then considered the matter and the ruling from the Administrative Law Judge.

Analysis:  The Administrative Law Judge (and NLRB) recognized that there is a line of precedent which stipulates that “the Act [NLRA] guarantees to each employee the right to determine for himself, free from coercion, whether he shall sign a checkoff authorization form or not.”  Consequently, the employee’s refusal to sign the checkoff authorization form prior to and during the meetings qualified as protected activity under the NLRA.

Turning to whether the employee’s statements/outburst forfeited the protections of the NLRA, the four factor test from the NLRB’s 1975 Atlantic Steel Co. decision was considered.  To determine whether an employee’s conduct forfeited the protections of the NLRA, four factors are analyzed:  1) the place of the discussion; 2) the discussion’s subject matter; 3) the nature of the outburst on the part of the employee; and 4) whether the outburst was provoked by the employer’s unfair labor practices.  Let us take a look at each:

The Place of the Act

At the meeting in which the employee’s outburst occurred, it took place in the manager’s office, away from other employees.  Only managers or supervisors were present, rather than co-workers.  Based upon the evidence in the record, there was no indication that other employees saw or heard what occurred.  As a result, it was held that the employee’s outburst did not occur in front of other employees which would have been more difficult for Alle to tolerate.

The Subject Matter of the Discussion

The whole purposed of the meeting was to discuss the employee’s refusal to sign the checkoff form.  As the employee had long been against joining the union and refused to sign the form on several occasions, his outburst occurred during his “attempted assertion of a fundamental right under the Act [NLRA].”

The Nature of the Outburst

While the NLRB did not condone or approve of the employee’s obscene gesture or comments, it recognized that Alle had no policy against profanity and had previously tolerated profanity by employees (even when it had been directed toward supervisors.)  Interestingly enough, the NLRB found that the employee’s comment that he was a “streets guy” to be too vague to amount to a threat. 

Whether the Outburst Was Provoked

The NLRB agreed with the finding of the Administrative Law Judge that the employee’s conduct occurred as a result of coercive conduct by Alle.  A line of precedent has held that attempts to coerce an employee to execute a checkoff authorization form constitutes a violation of Section 8(a)(1) of the NLRA.

The Takeaway:  Let us remember that the NLRB is not giving workers the green light to flip tables, denigrate their employers with profanities, and go ballistic in the workplace without risking losing the protections afforded under the NLRA.  Instead, the court factor test from Atlantic Steel Co will be applied to the facts of a given case to see if the protections of the NLRA were forfeited.  In this instance I think the Administrative Law Judge and NLRB got it right...but as noted, each situation is different and “results may vary.”  Workers:  take heed.  

Date:  April 2, 2020


Comments

Popular posts from this blog

NLRB: Discussion Among Employees About Tip Pooling is Protected Concerted Activity

  This Advice Memorandum from the National Labor Relations Board’s Associate General Counsel, Jayme Sophir, addressed whether employees which discussed and complained about tip pooling at work constituted protected concerted activity. In relevant part, an employer in New York operated a chain of steakhouses.  While tip pooling was in place at these steakhouses, some of the employees objected to it on the grounds that it was not transparent and improperly divided tips among the workers.  Employees were told not to complain or talk to each other about the tip pool and were told that doing so would endanger their jobs.  Despite the employer later attempting to provide some clarity as to how the tips were being divided, rancor still existed among some employees.  At one point, the employees were told by a general manager that some employees that had been talking about the tip pool were “cleared out” and the employer would continue to do so. In the Advice Memorandum, it was noted that emplo

What I’ve Been Reading This Week

A few years ago, I remember when the “Fight for $15” movement was taking off around the country.  Lo and behold, it appears that a $15/hour minimum wage is not the stopping point, which should be no surprise.  As the below article notes, New York is aggressively moving to ramp up hourly wage rates even higher.  While all the  below articles are worth a read, I called particular attention to that one. As always, below are a couple article that caught my eye this week. Disney World Workers Reject Latest Contract Offer Late last week, it was announced that workers at Disney World had rejected the most recent contract offer from the company, calling on their employer to do better.  As Brooks Barnes at The New York Times writes, the unions that represent about 32,000 workers at Disney World reported their members resoundingly rejected the 5 year contract offer which would have seen workers receive a 10% raise and retroactive increased back pay.  While Disney’s offer would have increased pa

Utah Non-Compete Bill Falters in House

Last month, a non-compete bill sponsored by Representative Brian Greene (Republican from Pleasant Grove) & up for vote in the Utah House failed to make it through the Legislature.  The bill sought to ban enforcement of non-competes if they came after a worker was already employed, given no compensation (such as a bonus or promotion) for signing the non-compete, and laid off within six months.  However, by a 22 - 49 vote, the bill was resoundingly defeated after some business groups lobbied to kill the non-compete bill.  One group in particular, The Free Enterprise Utah coalition, argued that the Utah State Legislature should hold off on any changes to non compete laws in the state until a survey about non competes was done among Utah businesses.  Representative Greene had countered this claim and argued that a survey was not needed to show that the current non compete laws in the states allowed many businesses, including some small high tech companies in the state, to per