United Nurses & Allied Professional v. National Labor Relations Board, No. 19-1490 (1st Cir. 2020)
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The First Circuit denied the petition filed by United Nurses and Allied Professionals (the Union) for review of the decision of the National Labor Relations Board (the Board) ruling that lobbying expenses are categorically not chargeable to objecting employees, holding that unions cannot require objectors to contribute toward lobbying costs.
Jeanette Geary worked as a nurse at a Rhode Island hospital where the Union was the exclusive bargaining representative. Geary challenged the Union's decision to charge her for some of its 2009 lobbying expenses and to refuse her a letter verifying that its expenses were examined by an independent auditor. The Board ruled in favor of Geary. The First Circuit upheld the decision, holding (1) the Board's decision on the Union's lobbying expenses comported with Supreme Court decisions addressing the changeability of lobbying expenses by public-sector unions; and (2) the Board's determination requiring the Union to provide Geary a letter signed by an auditor verifying that the financial information disclosed to the objectors had been independently audited was reasonable.
This opinion or order relates to an opinion or order originally issued on September 15, 2020.
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