Vitek Electronics, Inc. v. National Labor Relations Board

A. LEON HIGGINBOTHAM, Jr., Circuit Judge,

dissenting.

I.

This case presents the question whether the National Labor Relations Board (the Board) erred in certifying the International Union of Electrical, Radio and Machine Workers, AFL-CIO (the Union) after an election campaign in which it was alleged that the Union misrepresented material facts and intimidated employees.1 Vitek Electronics, Inc. (Vitek) argues that it did not have adequate time to respond to the Union’s misrepresentations and that certain threats made by the Union and its agents against Vitek employees necessitated a hearing before the Regional Director (RD) to determine if the “laboratory conditions” of the election were so polluted as to require the setting aside of the Union’s 70 to 45 victory.

The majority concludes that the RD and the Board erred by failing to grant Vitek a hearing. Thus, it ordered the Board to set aside the Union’s 25 vote majority and to conduct a hearing on Vitek’s objections. I have concluded that the Board could find that the Union’s statements were within the permissible range of campaign rhetoric and that Vitek failed to meet its burden of establishing the need for a hearing on the intimidation issue. While I am not suggesting that it would have been impermissible for the Board to have ordered a new election or to have had further hearings on Vitek’s complaints, I would hold that the Board was not required to order a new election and was not required to have any further hearings.

Whether one is considering elections on the national political scene or in the context of labor relations, it would be ideal if all the parties spoke the truth, the whole truth and nothing but the truth. It would be preferable that every statement given be precisely accurate and in no way misleading. But, reality tells us that such idyllic standards do not exist among vigorous adversaries who have much at stake riding on the outcome of an election. In any event, from media advertisements for consumer products, to extravagant promises made by political candidates, Americans are used to exaggerations, overstatements and distortions. And, as a consequence, working men and women are not so gullible that they necessarily believe that every statement uttered in election campaigns is precisely accurate. As Abraham Lincoln once wrote, “you can’t fool all of the people all the time.”

*796Congress has delegated to the Board the power to determine (1) whether a particular misstatement is sufficiently material so as to fool or mislead employees unfairly at the polling place and (2) whether another election, where hyperbole is reduced, is required. In all due respect, the majority opinion reflects what I believe to be a failure in this circuit clearly to differentiate or appreciate the limited role of appellate review in National Labor Relations Board cases. Simply stated, it is for the Board to gauge the effect of campaign polemic. We are not empowered to sit as a super-board to try de novo what are essentially findings of fact. In short, the majority decision steps over the boundary lines for appellate review and invades the role which Congress gave exclusively to the Board. I, therefore, respectfully dissent from the majority’s opinion.

I.

The burden is on the party seeking to overturn a Board-conducted representation election to establish that the election was not fairly conducted. N. L. R. B. v. Mattison Machine Works, 365 U.S. 123, 81 S.Ct. 434, 5 L.Ed.2d 455 (1961) (per curiam). Whether the challenged conduct tended to interfere with the employees’ free choice is to be determined primarily as a function of the Board’s discretion. N. L. R. B. v. A. J. Tower, 329 U.S. 324, 330, 67 S.Ct. 324, 327, 91 L.Ed. 322 (1946); N. L. R. B. v. Bancroft Mfg. Co., 516 F.2d 436, 439 (5th Cir. 1975), cert. denied, 424 U.S. 914, 96 S.Ct. 1112, 47 L.Ed.2d 318 (1976); N. L. R. B. v. Trinity Steel Co., 214 F.2d 120, 123 (5th Cir. 1954).

The Board’s basic policy is to seek to insure that in selecting a bargaining representative the employees have full and complete freedom of choice. The Board attempts, insofar as possible, to encourage laboratory conditions so that employees may exercise this right. Hollywood Ceramics, Inc., 140 NLRB 221, 224 (1962). Gross misrepresentations with regard to material issues in an election, however, can disrupt these conditions and interfere with the expression of free choice. Yet, neither absolutely precise statements nor complete honesty exist in most election campaigns, and they are not even expected by the employees. Election campaigns, after all, are often hotly contested matters prone to the overstatement of one’s own virtues, and the zealous condemnation of the other side’s vices. Thus, “the Board must balance the right of the employees to an untrammeled choice, and the right of the parties to wage a free and vigorous campaign with all the normal legitimate tools of electioneering.” Id.

Reflecting this balance, the Board recognizes that a certain amount of inaccuracy and ambiguity are endemic to campaign propaganda. Hence, to warrant setting aside an election, the Board requires that there be a substantial misrepresentation of a material fact, made by one with special knowledge of the true facts and communicated to the parties so shortly before the election that the other party has no opportunity to correct it. Id. at 223, 224. Moreover, the misrepresentation must involve facts about which the employees are not in a position to know the truth. General Knit of California, 239 NLRB (1978); Peerless of America, Inc. v. N. L. R. B., 576 F.2d 119, 123 (7th Cir. 1978). The mere fact “that a message is inartistically or vaguely worded and subject to different interpretations will not suffice to establish such misrepresentation as would lead [a court] to set [an] election aside.” Hollywood Ceramics Inc., 140 NLRB at 224. In fact, “even where a misrepresentation is shown to have been substantial, the Board may still refuse to set aside the election if it finds upon consideration of all the circumstances that the statement would not be likely to have had a real impact on the election.” Id. The rule could not be otherwise lest the losing party to an election be afforded too great an opportunity to delay the implication of the election results by litigating the accuracy of factual assertions which did not affect the election results. The application of this sound policy to the present facts in my view dictates that we enforce the Board’s certification order.

*797II.

Vitek objects to the Union’s campaign handbill entitled “IUE-Vitek News, No. 3.” In this leaflet, the Union asserted that the cost of living in America is rising at the rate of 14% and that at other plants in the area it has negotiated cost of living clauses that increase employee wages regularly “to keep pace with” the cost of living. The employer argues that the cost-of-living clauses are “capped” and “keyed” to formulas that do not guarantee cost-of-living adjustments equal to the actual rise in the cost of living. It contends and the majority apparently holds that this campaign document materially misrepresents the cost-of-living protective clauses the Union negotiated with three other employers and thereby establishes a prima facie case for setting aside the election. In so holding, the majority interprets this handbill to be a Union representation that the cost-of-living clauses in its contracts at Edison Products, Guitón Industries, and Delco Batteries guarantee cost-of-living increases equivalent to the actual rise in the cost-of-living. I do not agree.

The Board found that this handbill nowhere stated that any of its cost-of-living protective clauses would guarantee cost-of-living raises equal to the actual rise in the cost of living. The Company admits this. Nevertheless, it maintains that the employees interpreted the statement “to keep pace with the cost of living increase announced by the U. S. Department of Labor” as an absolute guarantee of “dollar for dollar” protection against inflation.2 I would hold that it was proper for the Board to interpret this statement not to provide such protection.

Furthermore, the Board recognized that the Union had in fact negotiated cost-of-living protective clauses with the companies in question that did provide their employees with some protection against inflation. Thus, although this document is “vaguely worded and subject to different interpretations,” Hollywood Ceramics, Inc., at 224, it is not sufficiently misleading to justify setting the election aside. The Board’s conclusion, therefore, in this regard is not so outlandish as to constitute an abuse of discretion. Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971).

Vitek also asserts that it did not have adequate time to respond to this document prior to the election. The document in question, however, invites the Company to speak to the employees at Union meetings on June 6,1979 (the day before the election) regarding the statements made by both parties during the campaign. Surely, had Vitek felt the matter important enough, it could have taken this opportunity to explain to its employees that the cost-of-living clauses were capped at a certain percentage or keyed to a specific formula that did not provide an absolute guarantee of “dollar for dollar” protection against inflation.

III.

The majority also objects to portions of the Union handbill entitled “A Story By and For Vitek Workers.” The majority attacks this handbill because it states that “Back in the ‘good ole’ days” the employer’s wages were the lowest in the area. I do not feel that the record in this case reveals this statement to be a material misrepresentation of fact. Indeed, Vitek initiated its uniform wage rates on January 2, 1976 *798(revising them thereafter on October 2, 1976) and offered no evidence to indicate that between January 2, 1976 and October 2, 1976 — before the Union came on the scene — its wages were not the lowest in the area. Hence, the Board could reasonably infer that such evidence did not exist.

Moreover, although as of April 15, 1979, Vitek did increase its minimum wage to about $1.00 more per hour than ten other area companies, this took place after the Union began its organization drive and had filed its representation petition on April 5, 1979. Accordingly, the Company’s comparison of its pay scales with those of other area companies after April 15, 1979 are irrelevant to us since these rates reflect a wage increase given to the employees after and not before the Union began to organize.3

In conclusion, I believe that given the circumstances of this case, the Board could find that the alleged misrepresentations by the Union are not so substantial as to be reasonably expected to have had a significant impact upon an election which the Union won by a margin of 70 to 45, an election in which they garnered 61% of the total vote. Therefore, the Board did not abuse its discretion in holding that the challenged conduct did not interfere with the employees’ free choice.

V.

Finally, the majority contends that “there is no adequate record here from which to tell whether the RD correctly determined that no hearing was necessary” on the question of whether the Union poisoned the pre-election atmosphere by intimidation. In support of this view, Vitek submitted into evidence the affidavits of several employees and supervisors, pinpointed several employees from whom affidavits were taken, and provided the names of numerous other employees whom it asserted had information relevant to its objections to the election. Vitek’s legal counsel, however, was advised that if the Company was unable to provide more specific details with respect to the potential testimony of 17 of *799its witnesses, they would not be interviewed. It is well established that the objecting party has the burden of supplying the Board with specific evidence that warrants setting aside an election before the. Board must pursue an investigation. See National Labor Relations Board Cashandling, Manual (Part Two) Section 11392.5. In fact, the objecting party has the burden of producing specific evidence tantamount to an offer of proof before the Board is required to hold an evidentiary hearing or pursue an investigation. Howard Johnson Company d/b/a Howard Johnson Distribution Center, 242 NLRB 1286 (1979).

The RD properly concluded in 'this instance that (1) upon the basis of the evidence as a whole the Company failed “to raise substantial or material issues with [regard] to conduct affecting the results of the election” and; (2) that since “no evidence was offered that any of the employees not interviewed possessed any relevant information which would raise material or substantial issues concerning conduct affecting the results of the election, the Board agents acted in accordance with established Board policy in refusing to interview” the employees in question. In this light, the Board has held that

. . . where an objecting party presents prima facie evidence demonstrating that the election was not fairly conducted, we do not hesitate to make the necessary investments of time and money, nor can we then avoid the concomitant delay in making our procedures effective. On the other hand, where there has been no prima facie showing of misconduct ... [it] ... is not only proper but necessary to prevent dilatory tactics by employers or unions disappointed in the election returns.

Newport News Shipbuilding and Dry Dock Company, 239 NLRB 82, 83-84 (1978).

VI.

For the foregoing reasons, I would deny the petition to review and set aside and grant the cross-application for enforcement of the Order of the National Labor Relations Board.

. The alleged misrepresentations concerned cost-of-living clauses, wages, job safety, seniority and job security.

. In fact, Vitek argues that the handbill guarantees a “dollar for dollar” cost of living increase despite the fact that the leaflet contains the following comment with respect to former President Carter’s 7% wage controls:

FLASH
A federal court has just upheld the IUE-AFL-CIO lawsuit charging that President Carter’s 7% wage controls are illegal.
This is an important step forward in the union’s fight to see that workers at plants such as Vitek are not held down at this time when the cost of living is going up at a rate of 14%.
IUE has performed a service, not just for its own members, but for workers throughout the country, by fighting against wage controls. It shows the strength of our union and our concern for the needs of working people.

. I would also conclude that it was proper for the Board to find that this Union handbill did not materially misrepresent the Company’s policies with regard to its safety precautions, or its seniority and discharge programs. In short, the Board found that the Union’s campaign statement that “few safety precautions were taken to protect the people from carbon monoxide fumes and when [people] got sick because of the fumes, many of [them] lost pay” was not a material misrepresentation of fact.

In this regard, Vitek argues that extensive safety precautions had been taken and all employees reimbursed for time lost due to the fumes. Yet when the Company was requested to support its assertion with regard to the extensive safety precautions, it was only able to demonstrate that as of February 12, 1979 it had installed a new vent “to increase the amount of outside air entering the plant when the exhaust fans were on.”

Second, Vitek’s records indicate that on the day the new vent was installed, February 12, 1980, ten employees were sent to a local hospital’s emergency room and then home by a doctor due to fume-induced sickness. On February 16 and February 26, 1979, 30 employees and seven employees, respectively, left work due to what they believed to be fume-induced illness. Hence, it was reasonable for the Board to infer that one fresh air vent had not solved the problem.

Third, the record shows that at least ten employees who felt they were suffering from a fume-induced illness, were not paid for all of their lost time. The Company unilaterally determined that seven of these employees failed to substantiate their claim of illness and that no reason existed for it to believe there was a problem with the heating system at the time. But, just because this is Vitek’s view, the Board was hardly compelled to believe that, therefore, the Union’s opposing view was a material misrepresentation of fact.

In any event, the Union’s statements about safety precautions involved matters within the context of the employee’s working environment. Thus, the employees were in a position to possess independent knowledge with which to evaluate these statements.

Finally, I also would hold that the Board properly found that the Union did not materially misrepresent the Company’s seniority and discharge policies. The Union asserted in its leaflet that before it came on the scene seniority had no effect on promotions and overtime and that employees could be fired with no chance of appeal. Vitek did institute a seniority job-posting program and a grievance procedure on April 2, 1979. But, the Company presented absolutely no evidence that it had a seniority job-posting program or grievance procedure prior to April 2, 1979 — that is before the Union began its campaign.