The day after Auciello Iron Works' contract offer was accepted by its union employees' collective-bargaining representative, Auciello disavowed the agreement because of a good-faith doubt, based on knowledge acquired before the offer's acceptance, that a majority of employees supported the Union. The National Labor Relations Board (NLRB) ruled that Auciello's withdrawal was an unfair labor practice in violation of the National Labor Relations Act and ordered that the agreement be reduced to a formal written instrument. The Court of Appeals enforced the order as reasonable after the NLRB issued a supplemental opinion to justify its refusal to consider Auciello's defense of good-faith doubt about the Union's majority status.
May an employer disavow a collective-bargaining agreement because of a good-faith doubt about a union's majority status at the time the contract was made, when the doubt arises from facts known to the employer before its contract offer had been accepted by the union?
No. In a unanimous opinion delivered by Justice David H. Souter, the Court held that the NLRB reasonably concluded that an employer challenging an agreement under these circumstances commits an unfair labor practice in violation of the National Labor Relations Act. The Court agreed with the NLRB that an employer's precontractual, good-faith doubt is inadequate to support an exception to the conclusive presumption of a union's majority status, which arises at the moment when a collective-bargaining contract offer has been accepted.
Decisions
Decision: 9 votes for National Labor Relations Board, 0 vote(s) against Legal provision: National Labor Relations, as amended
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Full Opinion by Justice David H. Souter
