United States Court of Appeals
For the First Circuit
No. 04-2071
SOCIEDAD ESPAÑOLA DE AUXILIO MUTUO Y BENEFICIENCIA DE P.R.
A/K/A HOSPITAL ESPAÑOL AUXILIO MUTUO DE PUERTO RICO, INC.,
Petitioner, Cross-Respondent,
v.
NATIONAL LABOR RELATIONS BOARD,
Respondent, Cross-Petitioner.
PETITION FOR REVIEW OF AN ORDER OF
THE NATIONAL LABOR RELATIONS BOARD
Before
Selya, Circuit Judge,
Baldock,* Senior Circuit Judge,
and Howard, Circuit Judge.
Julio I. Lugo Muñoz, with whom Lespier, Muñoz Noya & Rivera
was on brief, for petitioner.
William M. Bernstein, Senior Attorney, with whom Arthur F.
Rosenfeld, General Counsel, John E. Higgins, Jr., Deputy General
Counsel, John H. Ferguson, Associate General Counsel, and Aileen A.
Armstrong, Deputy Associate General Counsel, were on brief, for
respondent.
July 8, 2005
*
Of the Tenth Circuit, sitting by designation.
HOWARD, Circuit Judge. In this case, we consider a
petition for review and cross-petition for enforcement of an order
of the National Labor Relations Board. The order charged the
petitioner, Sociedad Española de Auxilio Mutuo Y Benficencia de
Puerto Rico (Hospital), with four unfair labor practices under the
National Labor Relations Act, 29 U.S.C. § 151 et seq., for its
dealings with the Unidad Laboral de Enfermeras y Empleados de la
Salud (Union). The Hospital challenges the Board's ruling on each
alleged violation. We enforce the Board's order.
I. Procedural Background
The Hospital is a tertiary care institution located in
San Juan, Puerto Rico. The Union has been the certified
representative of the Hospital's registered nurses since 1977. In
December 1994, 150 technical employees, including respiratory
therapists and radiology technicians, voted to join the Union. The
Hospital filed objections to the election, but the Board certified
the Union as the representative of these employees in January 1997.
Approximately eighteen months later, collective bargaining began
with the technical employees.
In December 1999, the NLRB General Counsel filed a
complaint against the Hospital alleging that it had committed five
unfair labor practices. The complaint alleged that the Hospital
had (1) unlawfully enforced a no-solicitation/no-distribution
policy against a unionized employee; (2) told employees it was
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going to lock them out in retaliation for their union activities;
(3) sought to encourage employees to decertify the Union; (4) fired
an employee for her union activities; and (5) subcontracted union
work without providing prior notice to the Union and without
affording the Union the opportunity to bargain over the
subcontracting decision.
In October 2000, an administrative law judge (ALJ) held
a six-day hearing on these allegations. Just over a year later,
the ALJ issued an opinion and order finding that the Hospital had
committed all five of the alleged unfair labor practices. The
Hospital filed exceptions with the Board as to each finding. The
Board affirmed the ALJ's ruling except for the finding concerning
the Hospital's threat to lock out its employees. Thus, the final
Board order found that the Hospital had committed unfair labor
practices concerning its termination of an employee, its unlawful
enforcement of a no-solicitation policy, its effort to decertify
the Union, and its subcontracting of Union work. The Hospital
timely petitioned for review in this court, and the General Counsel
cross-petitioned for enforcement of the Board's order.
II. Standard of Review
The case turns primarily on whether the facts in the
record support the Board's determinations. We are required to
accept the Board's factual findings so long as they are "supported
by substantial evidence on the record considered as a whole." 29
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U.S.C. § 160(e); NLRB v. Hosp. San Pablo, Inc., 207 F.3d 67, 70
(1st Cir. 2000). Substantial evidence is "such relevant evidence
as a reasonable mind might accept as adequate to support a
conclusion." NLRB v. Beverly Enterprises-Mass., Inc., 174 F.3d 13,
21 (1st Cir. 1999). "The possibility of drawing two inconsistent
conclusions from the evidence does not prevent [the Board's]
finding from being supported by substantial evidence." American
Textile Mfrs. v. Donovan, 452 U.S. 490, 523 (1981). The ultimate
question is "whether on this record it would have been possible for
a reasonable jury to reach the Board's conclusion." Allentown Mack
Sales & Serv., Inc. v. NLRB, 522 U.S. 359, 366-67 (1998).
III. Discussion
A. Discharge of Elsa Romero
We begin by considering the Board's finding that the
Hospital violated section 8(a)(3) of the Act by firing Elsa Romero,
a respiratory therapist, because of her union activities. See 29
U.S.C. § 158(a)(3). The Hospital claims that the Board's decision
is not supported by substantial evidence because the proof was
overwhelming that the Hospital terminated Romero because of her
failure to follow Hospital rules.
"An employer violates section 8(a)(3) by punishing an
employee for engaging in pro-union or other protected activities."
E.C. Waste, Inc. v. NLRB, 359 F.3d 36, 41 (1st Cir. 2004). But an
employer is free to terminate a union enthusiast so long as it
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applies its usual disciplinary standards and procedures. See
Wright Line v. NLRB, 662 F.2d 899, 901 (1st Cir. 1981). "Whether
or not a particular dismissal crosses the line typically depends on
the employer's motive." E.C. Waste, 359 F.3d at 41.
The Board and courts have applied a burden-shifting
approach in evaluating whether a particular termination violates
section 8(a)(3). Under this approach, the General Counsel must
first establish a prima facie case by demonstrating (i) the
employee's engagement in protected activity, (ii) the employer's
knowledge of that activity, (iii) that the employer harbored animus
toward unions, and (iv) a causal link between the anti-union animus
and the termination. See Hosp. San Pablo, 207 F.3d at 71.
If the General Counsel meets this initial burden, the
burden shifts to the employer to prove, by a preponderance of the
evidence, that it would have followed the same course of action in
the absence of the employee's union activities. See E.C. Waste,
359 F.3d at 42. Importantly, "even if the employer proffers a
seemingly plausible explanation, . . . the Board does not have to
accept it at face value. If the Board supportably finds that the
reasons advanced by the employer are either inadequate or
pretextual the violation is deemed proven." Id.
The Hospital has not challenged the Board's finding that
the General Counsel established the prima facie case so we will
focus primarily on the evidence concerning the Hospital's claim
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that it fired Romero for cause. Romero was hired by the Hospital
as a respiratory therapist in 1995. She was an active Union
member. She served as shop steward and was a member of the Union's
collective bargaining committee. During the course of her
employment, her supervisor, Carmen Martinez (Supervisor Martinez),
told Romero that she should be less visible in demonstrating her
support for the Union by limiting her press exposure as a Union
supporter. The ALJ characterized this statement as a "veiled
threat" that Romero should curtail her union activities or possibly
suffer adverse employment consequences. Nevertheless, in December
1997, Romero was rated as an excellent employee and received a 3.9
out of a possible 4.0 on her year-end evaluation.
Ten months later, Romero was fired. The termination
letter, dated October 26, 1998, charged Romero with falsely
claiming that she performed respiratory therapies on two patients
during the night of October 18, 1998. It also cited two reports of
Romero's insubordinate behavior subsequent to the October 18th
incident and referenced a previous disciplinary charge against
Romero dating to mid-1997.
On October 18th, Romero had reported to work for the 3
p.m. to 11 p.m. shift. There was a shortage of respiratory
therapists that evening so the supervisor on duty, Minerva Ruiz,
asked Romero to arrange for the coverage of additional patients.
Romero coordinated with fellow therapist Janice Martinez (Therapist
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Martinez) to cover the additional workload. Romero agreed that she
would treat the patients in rooms 275-335.
Romero testified that she followed the established
practices in performing her duties that evening. For each patient,
she read the medical orders, performed the prescribed therapy, and
then returned to the nurse's station, where she recorded the
therapy in a log called the "Respiratory Therapy Care Notes."
Romero testified that among her patients on the night of October
18th were the two patients occupying room 292. Romero stated that
she recorded the therapy for one of the patients on the patient's
notes from the prior day and, for the other patient, she recorded
the therapy on a blank page in the patient's notes instead of on
the page reserved for the October 18th treatments. Both Romero and
Supervisor Martinez agreed that, ideally, a therapist recorded the
therapies chronologically, but that the alternative recording
procedures described by Romero were commonplace.
On October 21, 1998, Supervisor Martinez noticed that
both Romero and Therapist Martinez claimed to have performed
identical services for the patients in room 292. Doubting that
both employees had performed the same services on a single shift,
Supervisor Martinez questioned Romero and Therapist Martinez about
the duplicate entries. Both employees claimed that they had
performed the services.
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To investigate the issue, Supervisor Martinez went to the
notes for the patients in room 292 and observed that Therapist
Martinez had recorded that she had performed the services in the
spaces reserved for October 18th. Supervisor Martinez did not,
however, review the remaining portions of the notes for these
patients to see if Romero had recorded the therapy in another spot.
After reviewing the October 18th entries, Supervisor
Martinez again confronted Romero, who reiterated that she had
performed the services on the patients in room 292. At this
encounter, Supervisor Martinez did not ask Romero where she had
recorded the therapies. Nor did she interview any of the other
employees on duty on October 18th to ascertain who had performed
the therapies on the patients in room 292.
As mentioned above, in addition to the October 18th
incident, Romero's termination letter referenced Romero's
insubordinate behavior subsequent to October 18th -- reports by a
nurse and shift coordinator claiming that Romero had acted
disrespectfully toward coworkers and superiors. Supervisor
Martinez admitted that she did not investigate either claim. The
termination letter also cited a suspension that Romero received in
mid-1997 for having another employee punch her time card.
On these facts, the Board determined that Romero's
termination was unlawful. The Board found that Supervisor
Martinez's investigations were inadequate. It concluded that
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Supervisor Martinez's failure to investigate thoroughly the charges
against Romero evidenced a rush to judgment motivated by anti-union
animus. It also concluded that the Hospital's reliance on a stale
disciplinary charge to justify the termination evidenced pretext.
The Hospital takes issue with the Board's conclusion that
Supervisor Martinez's conduct was improper and that it was wrong
for the Hospital to rely on the mid-1997 suspension as a basis for
firing Romero.
The conducting of an inadequate investigation of (or a
complete failure to investigate) the incident upon which the
employer relied as grounds for discharge can support a finding of
discriminatory motive. See, e.g., Cumberland Farms, Inc. v. NLRB,
984 F.2d 556, 560 (1st Cir. 1993). Whether a particular
investigation was sufficiently slipshod to support an inference of
discrimination is reviewed under the substantial evidence standard.
See Valmont Indus., Inc. v. NLRB, 244 F.3d 454, 466 (5th Cir.
2001).
Supervisor Martinez did not entirely ignore her
obligation to investigate the October 18th incident. She did talk
to the individuals directly involved in the incident and looked at
the most pertinent records. The Board concluded, however, that an
adequate investigation would have included a more detailed
interview with Romero, a more thorough investigation of the paper
record, and conversations with employees who may have had knowledge
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about the incident. Were we the initial factfinders, we might view
the adequacy of this investigation differently. But we are only
reviewing for substantial evidence, and on this record, we cannot
say that the Board's conclusion was beyond reason. See Universal
Camera Corp. v. NLRB, 340 U.S. 474, 488 (1957) (stating that Board
determination is entitled to affirmance "even though the court
would justifiably have made a different choice had the matter been
before it de novo").
In any event, the Board's conclusion is substantially
reinforced by the other reasons offered by the Hospital for
Romero's discharge. Supervisor Martinez conducted no investigation
into the charges of insubordination leveled against Romero and did
not even ask Romero for her position on the allegations. The
Hospital's reliance on completely uninvestigated charges to support
a termination suggests that the reasons given were pretextual.
See W.W. Grainger, Inc. v. NLRB, 582 F.2d 1118, 1121 (7th Cir.
1978).
Moreover, the Board was reasonable in concluding that the
Hospital's reliance on Romero's year-old suspension was probative
of pretext. See NLRB v. Q-1 Motor Express, Inc., 25 F.3d 473, 478
(7th Cir. 1994) (finding substantial evidence of discrimination
based in part on the employer's reliance on "stale" charges). Not
only was the violation over a year old, but it predated Romero's
outstanding 1997 performance evaluation. Cf. NLRB v. Hale
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Container Line, Inc., 943 F.2d 394, 400 (4th Cir. 1991) (affirming
Board finding that an employee's termination was pretextual where
the rationale offered by the employer was inconsistent with its
recent exemplary evaluation of the employee's performance). The
Hospital claims that it relied on this conduct because it favored
progressive discipline (i.e., increasing the severity of discipline
for each rules infraction). But, as the ALJ observed, the Hospital
"produced no evidence to show that it maintains and follows a
system of progressive discipline for its employees."
In sum, there was proof that Romero was a union activist
and that Supervisor Martinez harbored animus against her because of
her union activities. There also was proof that Supervisor
Martinez discharged Romero based on superficially investigated and
uninvestigated charges, and on a stale infraction that predated
Romero's recent outstanding performance evaluation. On these
facts, the Board's conclusion that Romero's termination violated
section 8(a)(3) is supported by substantial evidence.
B. Efforts to Decertify the Union
The Hospital's next challenge concerns the effort by a
Hospital supervisor to encourage employees to decertify the Union.
The Board has interpreted the Act to prevent an employer from
lending employees more than "ministerial aid" in their efforts to
file a decertification petition against a union. See Eastern
States Optical Co., 275 NLRB 371, 372 (1985); accord V&S ProGLAV,
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Inc. v. NLRB, 168 F.3d 270, 276 (6th Cir. 1999); NLRB v. United
Union Roofers, Local No. 81, 915 F.2d 508, 512 n.6 (9th Cir. 1990).
The Board found that the Hospital violated this
prohibition. The ALJ and the Board both credited the testimony of
Barbara Feliciano, a hospital employee and Union member. She
testified that, in the winter of 1999, she attended a meeting in
which a Hospital supervisor, Blanca Hernandez, explained to several
employees the procedure for decertifying the Union. Hernandez also
told the employees that they should sign the decertification
petition because they had lost benefits while unionized and that if
they decertified the Union, the Hospital would be able to give them
raises. Feliciano further testified that, after the meeting,
Hernandez called her into her office and asked her to sign a paper
containing a list of other employees who wanted to decertify the
Union. Hernandez denied that either of these meetings took place,
but the ALJ found her testimony incredible and the Board did not
disturb that finding.
The Hospital does not claim that Hernandez's conduct
constituted permissible "ministerial aid," even though the
parameters of this standard are not entirely clear. See Catherine
Meeker, Defining "Ministerial Aid": Union Decertification Under the
National Labor Relations Act, 66 U. Chi. L. Rev. 999 (1999); see
also Vic Koenig Chevrolet Inc. v. NLRB, 126 F.3d 947, 949 (7th Cir.
1997). Rather, it simply contends that the Board should have
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credited Hernandez's testimony. But it is a fundamental principle
that, absent a showing that "the ALJ overstepped the bounds of
reason," we will not disturb the ALJ's credibility determinations.
Ryan Iron Works, Inc. v. NLRB, 257 F.3d 1, 7 (1st Cir. 2001). The
Hospital has not come close to meeting this standard. The
conclusion that the Hospital violated the Act by encouraging
employees to decertify the Union is supported by substantial
evidence.
C. Enforcement of the No-Solicitation Rule
Section 7 of the NLRA guarantees employees "the right to
self-organization, to form, join or assist labor organizations,
[and] to bargain collectively through representatives of their own
choosing." 29 U.S.C. § 157. Section 8(a)(1) of the Act makes it
an unfair labor practice for an employer to interfere with an
employee's exercise of her section 7 rights. Id. § 158(a)(1).
The Supreme Court has long held that the right of
employees to communicate with one another regarding self-
organization at the job site is protected by Section 7.
See Republic Aviation Corp. v. NLRB, 324 U.S. 793, 798-99 (1945).
This right to communicate encompasses the right to distribute
union literature. Eastex, Inc. v. NLRB, 437 U.S. 556, 572-74
(1978). The Court has affirmed this right in the hospital setting.
See Beth Israel Hosp. v. NLRB, 437 U.S. 483, 507 (1977) (holding
that a hospital violates Section 8(a)(1) by preventing an employee
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from distributing union materials "during nonworking time in
nonworking areas, where the facility has not justified the
prohibition as necessary to avoid disruption of health-care
operations or disturbance of the patients").
The Board credited the testimony of Ana Melendez, a
hospital employee for over 25 years and the Union president.
Melendez testified that sometime in February 1998, she entered the
Hospital cafeteria for her lunch break and began to distribute
union literature. Shortly thereafter, a hospital security guard
intervened and prevented her from continuing. Based on this
testimony, the Board concluded that the Hospital violated section
8(a)(1) by restraining Melendez from distributing union material on
her nonwork time in a nonwork area. See Poly-America, Inc. v.
NLRB, 260 F.3d 465, 483 (5th Cir. 2001) (affirming unfair labor
practice based on security guard prohibiting employee from
distributing union literature). The Board's view is amply
supported by the record.
The Hospital attempts to defeat the Board's conclusion
by emphasizing that the Hospital disciplined Melendez for this
incident because of her conduct in addressing supervisors after the
encounter with the security guard. The Hospital asserts that she
was not subject to any discipline for attempting to distribute
Union material in the cafeteria. This argument entirely misses the
point. The unfair labor practice charged the Hospital with
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interfering with Melendez's right to distribute literature based on
the security guard's conduct. The claim before us has nothing to
do with whatever discipline Melendez received for her conduct after
the Hospital violated her section 7 rights.
D. Subcontracting Union Work
The final issue concerns the Hospital's subcontracting of
union work. Under section 8(a)(5) of the NLRA, 29 U.S.C. §
158(a)(5), an employer has a duty to bargain to impasse with its
employees over the terms and conditions of employment before making
a unilateral change in conditions. See Litton Fin. Printing Div.
v. NLRB, 501 U.S. 190, 198 (1991). The Supreme Court has held
that, in some cases, this requirement includes an employer's
decision to subcontract work that could be performed by members of
the bargaining unit. See Fibreboard Paper Prods. Corp. v. NLRB,
379 U.S. 203, 209-17 (1964). Failure to bargain over
subcontracting in such circumstances violates sections 8(a)(1) and
8(a)(5) of the Act. See Automatic Sprinkler Corp. of Am. v. NLRB,
120 F.3d 612, 616 (6th Cir. 1997).
The relevant facts are as follows. From August 1996
until the end of 2000, the Hospital subcontracted radiology
technician work from the night, weekend, and holiday shifts to a
company called GK Professional Services. Similarly, beginning in
1998, the Hospital subcontracted certain respiratory care work to
outside contractors for these same shifts. There is no dispute
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that the subcontracted work was identical to work performed by
members of the bargaining unit. The Hospital did not notify the
Union of its decision to subcontract this work. Nor did it
provide the Union with an opportunity to bargain over the
subcontracting decisions or their effects. The Board concluded
that this was a violation of the Hospital's duty to notify and
bargain with the Union before deciding to subcontract the radiology
technician and respiratory therapy work. See Torrington Indus.,
307 NLRB 809 (1992) (holding that employer unlawfully subcontracted
work unilaterally where the subcontracting involved nothing more
than the substitution of one group of workers for another to
perform the same work and does not constitute a change in the
scope, nature, and direction of the enterprise).
Citing Westinghouse Elec. Corp., 150 NLRB 1574 (1965),
the Hospital argues that it did not have an obligation to bargain
over the subcontracting decision because it had an established
practice of subcontracting this sort of work before the Union was
certified. But the operative date is not the date of union
certification (January 1997); it is the date of the election of the
Union (December 1994). See NLRB v. Westinghouse Broadcast & Cable,
Inc., 849 F.2d 15, 20-22 (1st Cir. 1988). Thus, for the Hospital
to benefit from the safe harbor for an established past practice of
subcontracting, the Hospital had to establish that it subcontracted
this work on a consistent basis prior to December 1994.
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The Board found that no such practice existed prior to
1994. One witness for the Hospital testified that the Hospital had
subcontracted this work well before 1994. But the ALJ declined to
credit this witness based on the Hospital's failure to produce any
pre-1994 agreements showing the subcontracting of respiratory
therapy or radiology technician work. Moreover, other witnesses
testified that, prior to 1994, the Hospital used per diem employees
to fill in when there was a shortage of respiratory therapists or
radiology technicians. We cannot fault the Board's conclusion that
the sporadic use of per diem employees is materially different from
subcontracting out entire shifts of work. Thus, the Board's
finding that there was no practice of subcontracting prior to
December 1994 is supported by substantial evidence.2
The Hospital also argues that, as a matter of law, it did
not have an obligation to bargain over its subcontracting decision
because no union employee was laid off or replaced as a result of
the subcontracting decision. Board precedent does not support the
Hospital's argument. See Acme Die Casting, 315 NLRB 202, 202 n.1
(1994) (holding that there is no requirement that the
2
Also relying on Westinghouse, supra, the Hospital argues that
it had no duty to bargain because the subcontracting was motivated
by economic concerns, namely, a shortage of workers willing to work
the night, weekend, and holiday shifts. This argument also
conflicts with the administrative findings of fact. The ALJ found
the testimony concerning the economic motive for the subcontracting
to be vague and lacking in credibility. The Board did not disturb
this finding. After reviewing the administrative record, we cannot
say that this conclusion was entirely without support.
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subcontracting result "in situations in which employees are laid
off or replaced" for it to be a mandatory subject of collective
bargaining).
In Puerto Rico Tel. Co. v. NLRB, 359 F.2d 983, 987 (1st
Cir. 1966), and W. Mass. Elec. Co. v. NLRB, 573 F.2d 101, 106 (1st
Cir. 1978), we held that subcontracting is not a mandatory subject
of collective bargaining unless the subcontracting results in the
displacement of union workers. We were careful, however, to base
our holdings on the ground that, at the time of decision, the Board
had never held that a subcontracting decision had to be bargained
over when there was no loss of union work. See W. Mass. Elec., 573
F.2d at 106 n.6. We recognized that because of the "possibly wide-
ranging implications" of expanding the circumstances in which
subcontracting would be a mandatory subject of bargaining, the
Board was the body best equipped to adopt such a rule. Id.
This approach of permitting the Board to take the lead in
developing the federal labor law is consistent with the Supreme
Court's conception of the role of the NLRB. As the Court has
explained:
The responsibility to adapt the Act to the
changing patterns of industrial life is
entrusted to the Board . . . . It is the
province of the Board, not the courts, [to
make adjustments in the governing law] in
light of changing industrial practices and
the Board's cumulative experience in
dealing with labor management relations.
[T]he Board has the special function of
applying general provisions of the Act to
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the complexities of industrial life, and
its special competence in this field is the
justification for the deference accorded
its determination. [Where the Board]
engages in the difficult and delicate task
of reconciling conflicting interests of
labor and management, the balance struck by
the Board is subject to limited judicial
review.
NLRB v. J. Weingarten, Inc., 420 U.S. 251, 266-67 (1974). After W.
Mass. Elec. was decided, the Board concluded that the NLRA does not
require a showing of job loss for subcontracting to be a mandatory
subject of collective bargaining. See Acme Die, 315 NLRB at 202
n.1. In light of this development, our task normally would be
limited to determining whether the Board's rule is a reasonable
construction of the Act.
There is good reason for the Acme Die rule. Union
members have an interest in an employer's subcontracting decision
in addition to the potential for layoffs. This work provides
bargaining unit members with the opportunity to obtain extra shifts
(possibly at overtime rates) or to expand the size of the unit
through the hiring of new employees. Considering these interests
(and possibly others), the Board has reasonably concluded that the
duty to bargain over subcontracting extends beyond the circumstance
where the employer's subcontracting decision will result in the
direct loss of union employment.
Finally, the Hospital contends that the Union waived its
right to complain about the unilateral subcontracting of work
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because the Hospital offered to bargain concerning the
subcontracting in January 2000, and the Union declined the
invitation. We disagree. The Hospital violated the Act by failing
to notify the Union of its subcontracting decision. See Penntech
Papers, Inc. v. NLRB, 706 F.2d 18, 27 (1st Cir. 1983). The
Hospital cannot cure this violation with a post-hoc offer to
negotiate. See id. The Hospital's offer to negotiate its
subcontracting decisions, several years after the decisions were
made, represents essentially an offer to negotiate over a "fait
accompli." Regal Cinemas v. NLRB, 317 F.3d 300, 314 (D.C. Cir.
2003). The offer was too little, too late.3
IV. Conclusion
For the reasons stated, we deny the Hospital's petition
for review and enforce the Board's order.
So ordered.
3
In a footnote to its brief, the Hospital asserts that the
Board erred in denying its motion to dismiss the subcontracting
claim involving the respiratory therapy work because of defects in
the General Counsel's complaint. As this point was raised only by
way of a cryptic footnote and is undeveloped, we will not consider
it. See Nat. Foreign Trade Council v. Natsios, 181 F.3d 38, 60
(1st Cir. 1999).
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