NATIONAL LABOR RELATIONS BOARD V. VALLEY HEALTH SYSTEM, LLC DBA DESERT SPRINGS HOSPITAL MEDICAL CENT, No. 23-137 (9th Cir. 2024)
Annotate this CaseThe United States Court of Appeals for the Ninth Circuit ruled that employers cannot unilaterally stop deducting union dues from employee paychecks after the expiration of a collective bargaining agreement. The case involved Valley Hospital Medical Center and Desert Springs Hospital Medical Center (collectively known as the "Hospitals") and the Service Employees International Union, Local 1107 ("the Union”). The Union and the Hospitals had entered into collective bargaining agreements that included checkoff provisions requiring the Hospitals to deduct union dues from participating employees’ paychecks and to remit those dues to the Union. After the agreements expired, the Hospitals ceased dues checkoff, arguing that the written assignments authorizing this did not include express language concerning revocability upon expiration of the collective bargaining agreement. They believed this omission violated the Labor Management Relations Act, also known as the Taft-Hartley Act. The Union filed unfair labor practice charges, and the National Labor Relations Board determined that the Hospitals had committed an unfair labor practice by unilaterally ceasing dues checkoff. The court held that the Taft-Hartley Act did not require specific language in the written assignments, so the Hospitals could not rely on that statute to justify their unilateral action. Consequently, the court granted the Board’s application for enforcement, denied the Hospitals' petition for review, and enforced the Board’s order in full.
Court Description: Labor Law The panel granted the National Labor Relations Board’s application for enforcement, denied Valley Hospital Medical Center, Inc.’s petition for review, and enforced the Board’s order finding that the Hospitals engaged in an unfair labor practice by unilaterally ceasing union dues checkoff.
Employees who wished to authorize dues checkoff signed a written assignment authorizing the Hospitals to deduct and to remit the employees’ union dues to the Union. After the collective bargaining agreements expired, the Hospitals ceased union dues checkoff because the employees’ written assignments did not include express language concerning revocability upon expiration of the collective bargaining agreements. Reversing an earlier decision, the Board held that the National Labor Relations Act prohibits employers from unilaterally ceasing dues checkoff after the expiration of a collective bargaining agreement. The Board reasoned that the Taft-Hartley Act did not require specific language in the employees’ written assignments, so the Hospitals could not rely on that statute to justify their unilateral action.
The Hospitals argued that they did not engage in an unfair labor practice because the written assignment signed by their employees did not comply with the Taft-Hartley Act. The Taft-Hartley Act prohibits employers from paying unions, but Section 302(c)(4) creates an exception permitting dues checkoff with the conditions that participating employees must authorize dues checkoff in a written assignment and must be given an opportunity to revoke that assignment at least once a year and upon expiration of the applicable collective bargaining agreement.
At issue is whether an employee’s checkoff assignment must reflect section 302(c)(4)’s revocability requirements. The panel held that nothing in section 302(c)(4)’s language dictates the terms that must be used in a written assignment.
Accordingly, the Hospitals were not required by the Taft- Hartley Act to cease dues checkoff, and the Board correctly applied the law to determine that the Hospitals committed an unfair labor practice by unilaterally ceasing union dues checkoff.
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