The summary of NLRB decisions for the week of March 28 – April 1 is now available. Summarized Board DecisionsVHS of Michigan, Inc. d/b/a Detroit Medical Center (07-CA-162818; 363 NLRB No. 155) Detroit, MI, March 29, 2016.The Board granted the General Counsel’s motion for summary judgment in this test-of-certification case on the ground that the Respondent failed to raise any issues that either were not, or could not have been, litigated in the underlying representation case. In that case, the Regional Director certified the Union as the exclusive collective-bargaining representative of the Respondent’s client service representatives I and II as part of an existing unit of laboratory and senior laboratory assistants. The Board noted that the Respondent made clear that it refused to bargain in order to seek judicial review of the certification. Although requested by the General Counsel, the Board declined to extend the certification year under Mar-Jac Poultry Co., 136 NLRB 785 (1962), finding that remedy inappropriate in cases involving self-determination elections conducted in accordance with Globe Machining & Stamping Co., 3 NLRB 294 (1937), and Armour & Co., 40 NLRB 1333 (1942).Charge filed by Local 283, International Brotherhood of Teamsters (IBT). Members Miscimarra, Hirozawa, and McFerran participated.
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