National Labor Relations Board v. Maine Coast Regional Health Facilities, No. 20-1589 (1st Cir. 2021)Annotate this Case
The First Circuit granted the application of the National Labor Relations Board for enforcement of one of its orders and struck those portions of the order requiring Maine Coast Regional Health Facilities, d/b/a Maine Coast Memorial Hospital (MCMH) to post repudiation notices at facilities operated by other corporate entities, holding that the Board improperly extended its remedy to MCMH's parent corporation.
The Board concluded the MCMH violated violated federal labor laws but firing an employee after she wrote a letter to the editor of a local newspaper and committed a separate violation by maintaining a media policy prohibiting contact between employees and the media. The Board extended its remedy to Eastern Maine Healthcare Systems (EMHS), MCMH's parent corporation, which was not a party to the proceeding. The Board then sought enforcement of its order. The First Circuit granted the application but struck the pertinent portions of the order, holding that there was no basis for concluding that EMHS was joined as a party or that MCMH consented to extending the remedy beyond its corporate borders.