Nevada Security Innovations,Ltd

National Labor Relations Board - Administrative Judge Opinions

Dec 22, 2003

31-CA-026020 (N.L.R.B. Dec. 22, 2003)

JD(SF)–94–03
Los Angeles and
Orange Counties, CA

UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
SAN FRANCISCO BRANCH OFFICE

NEVADA SECURITY INNOVATIONS, LTD.

and Case: 31-CA-26020

FEDERATION OF POLICE, SECURITY,
& CORRECTION OFFICERS - AFSPA

Ann J. White, Esq. Los Angeles, CA,
for the General Counsel.

Norman H. Kirshman, Esq. (Kirshman Harris
& Rosenthal), Las Vegas, NV,
for the Respondent.

Sidney H. Kalban, Esq., New York, NY,
for the Union.

DECISION

Statement of the Case
JAY R. POLLACK, Administrative Law Judge: I heard this case in trial at Los Angeles,
California on October 20, 2003. On November 14, 2002, Federation of Police, Security and
Correction Officers - AFSPA (the Union) filed the charge in Case 31-CA-26020 alleging that
Nevada Security Innovations, Ltd. (Respondent) committed certain violations of Section 8(a)(5) and
(1) of the National Labor Relations Act, as amended (29 U.S.C. Section 151 et seq., herein called
the Act). On December 30, 2002, the Acting Regional Director for Region 31 of the National Labor
Relations Board issued a Complaint and Notice of Hearing against Respondent, alleging that
Respondent violated Section 8(a)(5) and (1) of the Act. Respondent filed a timely answer to the
complaint, denying all wrongdoing.

On August 1, 2002, the Union was certified as the exclusive collective bargaining
representative of Respondent’s security officers employed at various federal agencies, locations
and facilities. See Nevada Security Innovations, 337 NLRB 1108 (2002). The complaint alleges
that the Union is the certified collective-bargaining representative of a unit of Respondent’s security
officers and that Respondent violated Section 8(a)(5) and (1) by failing and refusing to bargain with
the Union on request. Respondent filed a Motion for Summary Judgment with the Board and the
General Counsel filed a Cross-Motion for Summary Judgment. Respondent raised in its Motion for
Summary, inter alia, a defense that after certification of the Union, the Union transferred its
bargaining rights to an affiliated local union, Local 2001. Therefore, Respondent argued that it had
no obligation to bargain with the Union. The General Counsel alleged that the Union remained the
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exclusive collective-bargaining representative at all times since certification. The Union specifically
denied that a transfer of bargaining rights occurred.

On May 29, 2003, the Board issued an unpublished order denying both motions for
summary judgment. The Board found “that neither the Respondent nor the General Counsel has
shown that there is no genuine issue of material fact as to whether the Union transferred its
bargaining rights.” The Board stated “for this reason alone, we deny the General Counsel’s Cross-
Motion for Summary Judgment.” For that reason, and for other reasons, not relevant to this
decision 1, the Board denied the Respondent’s Motion for Summary Judgment.

Thus, the issue in the instant case is whether the Union transferred its bargaining rights to
Local 2001, thereby privileging Respondent’s refusal to bargain with the Union.

The parties have been afforded full opportunity to appear, to introduce relevant evidence, to
examine and cross-examine witnesses, and to file briefs. Upon the entire record, from my
observation of the demeanor of the witnesses,2 and having considered the post-hearing briefs of
the parties, I make the following:

Findings of Fact and Conclusions
I. Jurisdiction

Respondent is a Nevada corporation engaged in the business of providing security services
to various federal agencies in California and Nevada. In the 12 months prior to the issuance of the
complaint, Respondent received revenue in excess of $50,000 from the federal government. The
Board found, during the summary judgment procedure, that Respondent is an employer engaged
in commerce within the meaning of Section 2(2)(6) and (7) of the Act.

Respondent admits and the Board found that the Union is a labor organization within the
meaning of Section 2(5) of the Act.

II. Facts

As stated earlier, on August 1, 2002, the Board issued a decision and certification of
representative certifying the Union as the exclusive collective bargaining representative of
Respondent’s security officers in Los Angeles and Orange Counties, California, and overruling
Respondent’s objections to the Board conducted representation proceeding. At footnote 2 of the
Board’s decision, 337 NLRB 1108, the Board stated:

The Employer also contends that [the Union] should not be certified because it intends to
transfer its bargaining rights to [Local 2001]. The hearing officer rejected this contention
on the ground that it raises a ‘post-election matter.’ We agree. If any post-certification

1 The Board overruled defenses that Respondent raised in this proceeding, which had been,
previously dismissed in the representation proceeding.
2 The credibility resolutions herein have been derived from a review of the entire testimonial
record and exhibits, with due regard for the logic of probability, the demeanor of the witnesses,
and the teachings of NLRB v. Walton Manufacturing Company, 369 U.S. 404, 408 (1962). As to
those witnesses testifying in contradiction to the findings herein, their testimony has been
discredited, either as having been in conflict with credited documentary or testimonial evidence
or because it was in and of itself incredible and unworthy of belief.
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changes in bargaining representative were to occur, they may be addressed in
appropriate subsequent proceedings. See, e.g., Goad Co., 333 NLRB 677 (2001)
(employer did not violate Sec. 8(a)(5) when it refused to bargain after the statutory
bargaining representative transferred its representational responsibilities to another labor
organization). Here, it is not clear that [the Union] intended, upon certification, to
transfer its bargaining rights . . . If, after certification, [the Union] seeks to transfer
bargaining rights, the Board can deal with that in an appropriate case.

As stated earlier, upon cross motions for summary judgment, on May 29, 2003, the Board
ordered a hearing on the issue of whether the Union transferred its bargaining rights to Local
2001, after certification.

On August 15, 2002, the Union’s secretary-treasurer wrote Respondent requesting that
Respondent contact the Union to begin collective bargaining. On August 30, Respondent
through its attorney replied that the Board was in error in certifying the Union as bargaining
agent and that Respondent would not bargain with the Union “unless the certification is
determined to be enforceable.” On October 1, 2002, the Union again requested that
Respondent commence collective bargaining. On October 29, Respondent’s attorney denied
the request to bargain, challenging the Board’s certification.

On November 12. 2002, the Union entered into an agreement with its Local 2001 in San
Pedro, California providing that Local 2001:3

1. Hold meetings with the membership [the bargaining unit of Respondent’s
employees].
2. Make up mailings to the membership.
3. Work with the leadership of Nevada Security Innovations.
4. Keep up to date records of all complaints, unfair labor practices and other items that
need to be handled.
5. Keep the [Union] informed of [Local 2001’s] activities.

The last line of the agreement between the Union and its Local 2001 stated “As the certified
bargaining representative, the National will, of course, be in charge of negotiations once the
Company agrees to sit down and bargain.” On November 14, the Union filed the instant unfair
labor practice charge alleging a refusal to bargain by Respondent.

On December 5, 2002, Randy Brown, president of Local 2001, wrote Respondent
stating,

On November 13, 2002, [the Union] informed me that [the certified bargaining
unit employees] were now part of our local, Local 2001. It is as their representative that I
am now contacting you.

3 The Union’s small staff is located on the East Coast. The alleged purpose of the
November 12 agreement was to minimize travel expenses for the Union. Local 2001, on the
other hand, expected to obtain new members for Local 2001 as a result of its efforts.
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On December 1, 2002, the Local held its first united local meeting to discuss the
direction the Local would take in beginning the collective bargaining process. With that
in mind, we are requesting to meet with you to discuss issues of importance to the
officers, relative to their pay and benefits as well as working conditions, at the earliest
possible opportunity.

As a result of your previous refusal to recognize the vote and wishes of the
employees, we feel that it is imperative to advise you that should you not respond to this
notification to commence negotiations in good faith prior to December 31, 2002, the
Local will have no choice to consider initiation of job action.

Respondent did not answer Brown’s request for bargaining. On December 13, 2002, Brown
wrote the bargaining unit employees a letter entitled “welcome aboard” in which he stated that
the Union “was giving Local 2001 the opportunity to expand our service to our fellow Union
Brothers and Sisters.” Brown then welcomed the employees into Local 2001. Brown further
stated, “to commence our efforts to represent you, we have scheduled a meeting of the general
membership to familiarize you with the negotiation process.” On January 8, 2003, Brown
informed the members of Local 2001 that job action against Respondent was imminent. When
Respondent did not respond to Brown’s December 5 request to bargain, Brown organized some
job actions at the Los Angeles International Airport.

On January 10, 2003, Brown wrote the Federal General Services Administration a letter
in which he urged GSA not to renew its contract with Respondent “until such time as good faith
negotiations have taken place and a collective bargaining agreement is in place.”

While Brown is president of Local 2001, he holds no position with the Union. Brown
testified that before sending the December 5, 2002 letter requesting bargaining to Respondent,
he sent a draft of the letter to the Union’s then business manager.4 Brown received permission
to send the letter. Brown further testified that the shop steward for Respondent’s employees
had informed him that the unit employees had voted to become members of Local 2001.
Howard Johannssen, president of the Union, testified that the unit employees could choose to
be a separate local of the Union, members of an existing local of the Union, or members-at-
large of the Union. According to Johannssen, the Union had not yet conducted such a vote
among the unit employees. While Brown testified that the bargaining unit employees were
members of Local 2001, Johannsen testified that the unit employees were members of the
Union. In the absence of a collective-bargaining agreement, the bargaining unit employees
were not paying dues to either the Union or Local 2001.

I draw the inference that Brown and the business manager, expected that the bargaining
unit employees would become members of Local 2001 and that the Union and Local 2001
would share union dues pursuant to the Union’s procedures. However, this procedure would
take place after a collective-bargaining agreement was in place. Under the Union’s normal
procedures after the contract is reached, the employees can choose to be their own local,
affiliated with an existing local or members at large of the National Union.

On February 18, 2003, while the cross-motions for summary judgment were pending, the
Union’s secretary-treasurer, filed a declaration which stated, “so there can be no confusion . . .

4 The Union’s business manager died prior to the instant hearing. While the Union argues
that there is no evidence to corroborate Brown’s testimony that he received permission to send
the December 5 letter, I credit Brown’s testimony.
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FOSCO, the National Union, is the certified bargaining representative for the unit employees
and has never delegated authority elsewhere nor authorized any person or other entity to fulfill
that role.”

Analysis and Conclusions

Respondent argues that subsequent to the certification, Respondent transferred its
representational rights to Local 2001. It is well settled that it is the duty of an employer to
bargain solely with a statutory representative and no other person or group. However, a
bargaining representative "may . . . confer upon an agent . . . authority to act on its behalf."
Goad Company, 333 NLRB 667 (2001); Rath Packing Co., 275 NLRB 255, 256 (1985).
Employers and unions have the right "to choose whomever they wish to represent them in
formal labor negotiations." General Electric Co. v. NLRB, 412 F.2d 512, 516 (2d Cir. 1969).
Although a certified representative may delegate its duties under a contract, it cannot delegate
its responsibilities. Goad Co., Ibid; Mine Workers Local 17, 315 NLRB 1052, 1064 (1994); see
also Reading Anthracite Co., 326 NLRB 1370 (1998).

In Goad, the respondent-employer’s employees, for a number of years, were
represented by various locals of the Plumbers Union. Eventually, Local 420 became the
Plumbers Union’s local representing the respondent-employer’s employees. The president of
the Plumbers Union wrote the respondent-employer advising him that the Plumbers Union was
transferring jurisdiction over the bargaining unit employees to a different local, Local 562. The
respondent-employer subsequently refused to bargain with Local 562. An unfair labor practice
charge was filed against the respondent-employer and the regional director dismissed the
charge. That dismissal was upheld on appeal. Thereafter, in an effort to circumvent that
determination, Local 420 and Local 562 entered into an agreement in which Local 420
attempted to designate Local 562 as the agent of Local 420 for “negotiating and servicing” the
contract with the respondent-employer including “other actions comprising the duty of
representation.” In addition, the two locals executed a waiver absolving Local 420 for all liability
for Local 562’s actions.

The Board held that Local 429 did not simply enlist the aid of an agent; rather it
transferred its representational responsibilities to Local 562, which was not the certified
representative of the employees. The Board found that the respondent-employer had no
obligation to bargain with Local 562 and dismissed the complaint.

Prior to Goad, the Board, in Sherwood Ford, Inc., 188 NLRB 131 (1971), found no
obligation to bargain where a local union sought to substitute another local union as bargaining
agent. Sherwood Ford involved a local union, Local 1, whose leadership was inexperienced in
bargaining on behalf of automobile salesmen. That local sought to affiliate with Local 604, an
automobile salesmen's local. Refusal to bargain charges filed by Local 604 were dismissed
when the investigation disclosed that the affiliation vote among members of Local 1 was
defective due to a lack of notice. Thereafter, on August 21, 1968, the members of Local 1
ratified a resolution which designated Local 604 as the "duly constituted representative" of Local
1 "to appear on behalf of and represent" Local 1 in bargaining with Sherwood Ford, Inc." Id. at
132. Sherwood Ford refused to bargain with representatives of Local 604. The Board found no
violation and adopted the decision of the trial examiner whose discussion of the issue presented
stated:

As Respondent could not lawfully have recognized Local 604 as the bargaining
representative of the employees, we turn to the question whether it was required to
recognize that Local as the bargaining representative of Local 1. Setting aside for the
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moment the legalisms in which the resolution [in which Local 1 appoints Local 604] is
couched, the record otherwise fully supports Respondent's contention that the August 21
maneuver was a patent attempt to substitute Local 604 as the bargaining agent in place
of Local 1 and that it was a device, subterfuge, or stratagem by which the two locals
sought to circumvent the earlier rulings of the Regional Director [who had held there was
no obligation to bargain with Local 604].
. . .

Though the General Counsel cites authority for the familiar principle that a statutory
bargaining representative may select outside experts and other advisors as personnel of
its bargaining team, [footnoted omitted] the facts in the present case leave that principle
without application, for here the parties were attempting an outright substitution of
representatives, not just the association of expert aides. [Id. at 133, 134.]

In the instant case, the Union never notified Respondent that it had transferred its
jurisdiction or representational responsibilities to Local 2001. The Union never notified
Respondent that Brown or Local 2001 were its agents. Here, after Respondent’s attorney
notified the Union that Respondent would test the Board’s certification, the Union entered into
an agreement with its Local 2001 providing that Local 2001; hold meetings, make up mailings,
work with the employee leadership of Respondent, keep records and inform the Union of its
activities. The agreement clearly stated, “As the certified bargaining representative, the
National will, of course, be in charge of negotiations once the Company agrees to sit down and
bargain.”

Respondent had refused to bargain, citing disagreement with the certification, prior to
any demand to bargain by Brown.

General Counsel and the Union argue that Brown did not have authority to request
bargaining with Respondent. Section 2(13) of the Act, states: "In determining whether any
person is acting as an 'agent' of another person so as to make such other person responsible
for his acts, the question of whether the specific acts performed were actually authorized or
subsequently ratified shall not be controlling." In determining whether an individual is an agent
of the employer, the Board applies the common law principles of agency as set forth in the
Restatement (Second) of Agency Allegany Aggregates, 311 NLRB 1165 (1993); Dentech Corp.,
294 NLRB 924, 925-926 (1989). Under the doctrine of apparent authority, agency status may be
established where the employer's manifestations to a third party supply a reasonable basis for
the third party, to believe that the employer has authorized the alleged agent to do the acts in
question. Allegany Aggregates, supra, at 1165. Thus, either the employer must intend to cause
the third person to believe that the alleged agent is authorized to act for him, or the employer
should realize that its conduct is likely to create such belief. Service Employees Local 87 (West
Bay Maintenance), 291 NLRB 82, 83 (1988); Statements of the putative agent do not constitute
evidence of agency status. MPG Transport, LTD, 315 NLRB 489, 493 (1994), enfd. 91 F.3d 144
(6th Cir. 1996); Virginia Mfg. Co., 310 NLRB 1261, 1266 (1993), enfd. 27 F.3d 565 (4th Cir.
1994). While General Counsel and the Union argue that Brown acted outside his authority, the
evidence establishes that Brown sent a draft of his request to bargain to the Union’s business
manager and received permission to send the request to Respondent. Thus, the record here
establishes that Local 2001 (acting through Brown) was authorized by the Union’s business
manager to be the Union’s limited agent and to send the request to bargain.

The first issue is whether Brown was requesting bargaining on behalf of Respondent or
on behalf of Local 2001. Brown stated that the employees were part of his Local and that he
was requesting bargaining on their behalf. He stated that he was requesting bargaining based
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upon a meeting of the Local and threatened job action by the Local. He later initiated job action.
Based on Brown’s actions, Respondent could assume that Brown was seeking to substitute
Local 2001 as the bargaining representative. Thus, under Goad, and Sherwood Ford, supra,
Respondent could refuse to bargain with Local 2001.

In the instant case, as distinguished from Goad and Sherwood Ford, the General
Counsel seeks to compel the Respondent to bargain with the certified bargaining representative
and not a purported agent or substituted representative. The fundamental issue is whether
Respondent’s failure and refusal to bargain with the Union is excused by Brown’s request that
Respondent bargain with Local 2001. I conclude that it does not. Respondent was obligated to
bargain with the Union. It decided to test the Board’s certification and to refuse to bargain, prior
to Brown’s request to bargain. Thereafter, the Union agreed with Local 2001 that Local 2001
would act as its agent. However, that agency was expressly limited by the Union’s retention of
control over collective bargaining. Respondent could ignore a request to bargain by Local
2001, or any other labor organization, not the exclusive bargaining representative of the
employees. However, the Union remains the exclusive bargaining representative and did not
waive its right to bargain. Therefore, I find Respondent must still bargain collectively with the
Union. I further find that Respondent has failed to carry its burden of proving that the Union had
transferred its bargaining rights and responsibilities.

Conclusions of Law

1. Respondent is an employer engaged in commerce and in a business affecting
commerce within the meaning of Section 2(6) and (7) of the Act.

2. The Union is a labor organization within the meaning of Section 2(5) of the Act.

3. By failing and refusing on and after August 15, 2002, to meet and bargain with the
Union as the exclusive collective-bargaining representative of employees in the appropriate unit,
the Respondent has engaged in unfair labor practices affecting commerce within the meaning of
Section 8(a)(5) and (1) and Section 2(6) and (7) of the Act.

REMEDY

Having found that the Respondent has violated Section 8(a)(5) and (1) of the Act, I shall
recommend that it be ordered to cease and desist, to meet and bargain on request with the
Union, and, if an understanding is reached, to embody the understanding in a signed
agreement.

To ensure that the employees are accorded the services of their selected bargaining
agent for the period provided by the law, the Board shall construe the initial period of the
certification as beginning the date the Respondent begins to bargain in good faith with the
Union. Mar-Jac Poultry Co., 136 NLRB 785 (1962) ; Lamar Hotel, 140 NLRB 226, 229 (1962),
enfd. 328 F.2d 600 (5th Cir.1964), cert. denied 379 U.S. 817 (1964); Burnett Construction Co.,
149 NLRB 1419, 1421 (1964), enfd. 350 F.2d 57 (10th Cir. 1965).
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Upon the foregoing findings of fact and conclusions of law, and upon the entire record,
and pursuant to Section 10(c) of the Act, I hereby issue the following recommended: 5

ORDER

Respondent, Nevada Security Innovations, Inc., its officers, agents, successors and
assigns shall:

1. Cease and desist from:

a. Failing and refusing to meet and bargain with Federation of Police, Security and
Correction Officers-AFSPA as the exclusive bargaining representative of the
employees in the bargaining unit.

b. In any like or related manner interfering with, restraining, or coercing employees
in the exercise of the rights guaranteed them by Section 7 of the Act.

.
2. Take the following affirmative action necessary to effectuate the policies of the Act:

a. On request, meet and bargain with the Union as the exclusive representative of
the employees in the following appropriate unit on terms and conditions of
employment and, if an understanding is reached, embody the understanding in a
signed agreement:

Included: All full time and regular part time security officers employed at various
federal agencies locations and facilities as set forth in Attachment B to the
Stipulated Election Agreement.
Excluded: Office clerical employees, professional employees, all other
employees, supervisors (including lead security officers) as defined in the Act.

b. Within 14 days after service by the Region, post at its Facilities in Los Angeles
and Orange Counties, California, copies of the attached notice marked
"Appendix." 6Copies of the notice, on forms provided by the Regional Director for
Region 31, after being signed by the Respondent's authorized representative,
shall be posted by the Respondent and maintained for 60 consecutive days in
conspicuous places including all places where notices to employees are
customarily posted. Reasonable steps shall be taken by the Respondent to
ensure that the notices are not altered, defaced, or covered by any other
material. In the event that, during the pendency of these proceedings, the
Respondent has gone out of business or closed the facilities involved in these

5 All motions inconsistent with this recommended order are hereby denied. In the event no
exceptions are filed as provided by Sec. 102.46 of the Board’s Rules and Regulations, the
findings, conclusions, and recommended Order shall, as provided in Sec. 102.48 of the Rules,
be adopted by the Board and all objections to them shall be deemed waived for all purposes.
6 If this Order is enforced by a Judgment of the United States Court of Appeals, the words in
the notice "POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD" shall read
"POSTED PURSUANT TO A JUDGMENT OF THE UNITED STATES COURT OF APPEALS
ENFORCING AN ORDER OF THE NATIONAL LABOR RELATIONS BOARD."
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proceedings, the Respondent shall duplicate and mail, at its own expense, a
copy of the notice to all current employees and former employees employed by
the Respondent at any time since August 15, 2002.

c. Within 21 days after service by the Region, file with the Regional Director a
sworn certification of a responsible official on a form provided by the Region
attesting to the steps that the Respondent has taken to comply.

Dated: December 22, 2003, San Francisco, California.

_____________________
Jay R. Pollack
Administrative Law Judge

APPENDIX
NOTICE TO EMPLOYEES

Posted by Order of the
National Labor Relations Board
An Agency of the United States Government

The National Labor Relations Board has found that we violated Federal labor law and has ordered us to
post and obey this notice.

FEDERAL LAW GIVES YOU THE RIGHT TO

Form, join, or assist a union
Choose representatives to bargain with us on your behalf
Act together with other employees for your benefit and protection
Choose not to engage in any of these protected activities

WE WILL NOT refuse to bargain with Federation of Police Security and Correction Officers-AFPSA as the
exclusive representative of the employees in the bargaining unit.

WE WILL NOT in any like or related manner interfere with, restrain, or coerce you in the exercise of the
rights guaranteed you by Section 7 of the Act.

WE WILL, on request, meet and bargain with the Union and put in writing and sign any agreement
reached on terms and conditions of employment for our employees in the bargaining unit:

Included: All full time and regular part time security officers employed at various federal agencies
locations and facilities as set forth in Attachment B to the Stipulated Election Agreement.
Excluded: Office clerical employees, professional employees, all other employees, supervisors
(including lead security officers) as defined in the Act.

Nevada Security Innovations, LTD.
(Employer)

Date By
(Representative) (Title)

The National Labor Relations Board is an independent Federal agency created in 1935 to enforce the
National Labor Relations Act. It conducts secret-ballot elections to determine whether employees want
union representation and it investigates and remedies unfair labor practices by employers and unions. To
find out more about your rights under the Act and how to file a charge or election petition, you may speak
confidentially to any agent with the Board’s Regional Office set forth below. You may also obtain
information from the Board’s website: www.nlrb.gov.
11150 West Olympic Boulevard, Suite 700, Los Angeles, CA 90064-1824
(310) 235-7352, Hours: 8:30 a.m. to 5 p.m.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE

THIS NOTICE MUST REMAIN POSTED FOR 60 CONSECUTIVE DAYS FROM THE DATE OF
POSTING AND MUSTNOT BE ALTERED, DEFACED, OR COVERED BY ANY OTHER MATERIAL.
ANY QUESTIONS CONCERNING THIS NOTICE OR COMPLIANCE WITH ITS PROVISIONS MAY
BE DIRECTED TO THE ABOVE REGIONAL OFFICE’S - COMPLIANCE OFFICER, (310) 235-7123.