369 U.S. 736 (1962) Cited 710 times 29 Legal Analyses
Holding that "an employer's unilateral change in conditions of employment under negotiation" is a violation of the National Labor Relations Act because "it is a circumvention of the duty to negotiate"
In Rayner, the Board found the employer in violation of ยง 8(a)(1) and (5) and entered a remedial make-whole order that lasted beyond the end of the labor agreement.