Coffman v. Queen of the Valley Medical Center, No. 17-17413 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed a preliminary injunction pursuant to Section 10(j) of the National Labor Relations Act (NLRA), requiring the employer to engage in unconditional bargaining. The panel held that the Director has shown a sufficient likelihood of success in establishing a withdrawal of recognition and refusal to bargain unconditionally, as well as a continuing threat of irreparable harm to the union's collective bargaining rights, to support the extraordinary remedy of injunctive relief. In this case the record did not show that the employer had considerable dealings with the union following the union's certification, including discussions that resulted in agreements over some hours and working conditions, and that these negotiations took place before the employer made any official challenge to the certification.
Court Description: Labor Law / Preliminary Injunction. The panel affirmed the district court’s entry of a preliminary injunction, pursuant to Section 10(j) of the National Labor Relations Act (“NLRA”), requiring the employer to engage in unconditional bargaining with a union. The panel held that an employer cannot begin unconditional bargaining and later withdraw recognition because such actions interfere with the union’s collective bargaining rights protected by the NLRA. The panel held that the Regional Director of the National Labor Relations Board had shown a sufficient likelihood of success in establishing its underlying position that the employer recognized the union and engaged in unconditional bargaining before withdrawing recognition and refusing to bargain in violation of Section 8(a)(1) of the NLRA. The panel held that the Director established a continuing threat of irreparable harm to the union’s collective bargaining rights to support the extraordinary remedy of injunctive relief. The panel also held that the harm to the union outweighed the harm to the employer. The panel further held that the district court did not abuse its discretion in balancing the equities, and in finding that injunctive relief in this case was in the public interest. The panel held that the Director submitted sufficient evidence to establish a likelihood of success and irreparable COFFMAN V. QUEEN OF THE VALLEY MED. CTR. 3 harm with regard to the union’s claim that the employer discriminated against an employee for his union activity in violation of Section 8(a)(1) and (3) of the NLRA.
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