Perfection Automotive Products Corp.

National Labor Relations Board - Board Decisions

Sep 30, 1977

232 N.L.R.B. 690 (N.L.R.B. 1977)

DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Perfection Automotive Products Corporation and
Robert J. La Chance.
Local 299, International Brotherhood of Teamsters,
Chauffeurs, Warehousemen and Helpers of Ameri-
ca and Robert J. La Chance. Cases 7-CA-12830
and 7-CB-3509
September 30, 1977
DECISION AND ORDER
BY CHAIRMAN FANNING AND MEMBERS
JENKINS AND PENELLO
On December 15, 1976, Administrative Law Judge
Claude R. Wolfe issued the attached Decision in this
proceeding. Thereafter, Respondent Union filed
exceptions and a supporting brief, and the General
Counsel filed an answering brief to said exceptions.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the
National Labor Relations Board has delegated its
authority in this proceeding to a three-member panel.
The Board has considered the record and the
attached Decision in light of the exceptions and
briefs and has decided to affirm the rulings, findings,
and conclusions of the Administrative Law Judge
and to adopt his recommended Order.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the recommend-
ed Order of the Administrative Law Judge and
hereby orders that the Respondent Employer, Perfec-
tion Automotive Products Corporation, Livonia,
Michigan, its officers, agents, successors, and assigns,
and the Respondent Union, Local 299, International
Brotherhood of Teamsters, Chauffeurs, Warehouse-
men and Helpers of America, its officers, agents, and
representatives, shall take the action set forth in the
said recommended Order.
CHAIRMAN FANNING, dissenting:
Here the Board, by adopting the Administrative
Law Judge's Decision, finds that the continued
maintenance of a contract clause granting shop
stewards superseniority for all purposes is unlawful
because insufficient justification is shown. As stated
in my dissent in Dairylea Cooperative, Inc., 219
NLRB 656, 661 (1975), "I cannot accept my
colleagues' presumption that a collective-bargaining
agreement distinguishing between the benefits re-
ceived by union stewards and other employees in the
unit the steward serves violates the Act." The
applicability of this initial sentence from my dissent
232 NLRB No. 109
is intensified here, where the contract clause alone,
without having been applied on behalf of the
steward, is at issue.
As in Dairylea, the clause in question was negotiat-
ed in good faith by the parties and approved by the
employees, all of whom, except probationers with
less than 30 days' employment, are required under a
valid union-security clause to become and remain
members in good standing with the Union. Addition-
ally, the employees here have the right to elect their
stewards as well as the opportunity to be elected
steward. Moreover, the Respondent Union has
shown here that the existence of the clause, if
necessary to apply, would ensure a steward's contin-
ued presence on the job during overtime periods to
further the effective administration of the collective-
bargaining agreement by prompt, on the spot
resolution of disputes thereunder and the saving of
both time and money by the avoidance of the formal
use of the grievance procedure. There is thus
reasonable basis for approving the clause to the
extent, with respect to these parties, that the
administration of overtime policies is facilitated.
The illegality of the superseniority clause is
premised upon maintenance of the agreement. The
steward in question, because of his "actual" seniority
as found by the Administrative Law Judge, has had
no benefit from the admittedly broad superseniority
clause contained in the bargaining agreement.
Nevertheless my colleagues find a violation, appar-
ently because of the mere existence of the clause.
However, in IATSE, Local 780 (McGregor-Werner,
Inc.), supra, a panel majority did not find it necessary
to find a violation where a clause permitting shift
preference had never in fact been used. The clause
was held inoperative due to lack of use. I concurred
in that dismissal and would, of course, concur in a
dismissal here grounded on the clause not having
been applied.
In Dairylea a Board majority saw "no occasion for
finding super seniority-even that going beyond
layoff and recall-to be per se unlawful." Therefore, I
question the wisdom of what in this case I view as a
per se approach.
I For the reasons fully set out therein, we adopt the Administrative Law
Judge's Decision. Chairman Fanning in his dissent refers to the fact that the
steward, Turner, because of actual senionty did not benefit from the
supersenionty provisions of the contract. However, as stated by the
Administrative Law Judge, what is relevant is "the inherent tendency of
such clauses to discriminate against employees for union related reasons."
In addition, we believe that Chairman Fanning's reference to Motion Picture
Laboralory Technicians, Local 780, International Alliance of Theatrical Stage
Employees and Moving Picture Operators of the United States and Canada,
AFL CIO (McGregor-Werner, Inc.), 227 NLRB 558 (1976), is misplaced.
Not only was the shift preference supersenionrity clause never implemented,
but it was also shown to be a dead letter.
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PERFECTION AUTOMOTIVE PRODUCTS
DECISION
STATEMENT OF THE CASE
CLAUDE R. WOLFE, Administrative Law Judge: This
consolidated proceeding was heard before me at Detroit,
Michigan, on September 7, 1976, pursuant to charges duly
filed and served and consolidated complaint issued on
April 29, 1976. The Respondent Union timely filed its
answer thereto. The Respondent filed no answer prior to
the hearing and did not appear at the hearing in person or
by counsel. The Charging Party, La Chance, although
present prior to the opening of the record, left before the
hearing commenced and did not thereafter return.
At the opening of the hearing the General Counsel
moved for summary judgment against the Respondent
Employer because it had filed no answer to the complaint,
did not appear at the hearing, and its counsel had earlier
indicated to General Counsel that no answer would be
filed and no appearance would be made by the Respondent
Employer. Counsel for the Respondent Union then
proffered the Employer's answer to the complaint (with
copy to General Counsel), signed by the Employer's
attorney and dated September 7, 1976. The Union's
counsel explained that he had been requested to deliver
this document by the Employer's counsel who reported to
him that he could not be present due to other commit-
ments, and further explained that he was merely perform-
ing a courtesy and did not wish to appear as counsel for the
Respondent Employer. General Counsel, counsel for the
Union, and I examined the answer offered on behalf of the
Employer and ascertained that it raised no new issues.
After careful consideration, I admitted the Respondent
Employer's answer into evidence and denied General
Counsel's motion for summary judgment. I explained to
the General Counsel and the Union's counsel, on the
record, that I was exercising my discretion in this fashion
because (although a summary judgment might well be
appropriate were the Employer the only respondent and I
would probably grant one in that circumstance) the sole
matter in issue is the legality of a superseniority clause in
the collective-bargaining agreement between the Employer
and the Union, and if I were to grant judgment against the
Employer based on the pleadings such a ruling would raise
the possibility of an employer found guilty on the pleadings
and a union found innocent on the merits and this result, if
the clause be found legal in the Union's case, would be
unrealistic and seriously impede the administration of the
collective-bargaining agreement. I feel that in the peculiar
circumstances of the instant case, where a ruling against a
dilatory party might possibly seriously injure the interests
of an innocent party, my ruling was proper.
The Respondent Union and the Respondent Employer
(in its late filed answer), deny the commission of unfair
labor practices.
Upon the entire record, including my observation of the
witness,' and after due consideration of the posttrial briefs
I The General Counsel rested on the pleadings, after stating her position
that by maintaining in effect the contractual clause herein both Respon-
dents have committed an unlair labor practice under the authority of
Dairylea Cooperative, Inc., 219 NLRB 656 (1975). The Union called only one
witness, its steward. Lewis Turner. to testify in its defense.
filed by General Counsel and Respondent Union, I make
the following:
FINDINGS AND CONCLUSIONS
I. JURISDICTION
The complaint alleges, both Respondents admit, and I
find that Perfection Automotive Products Corporation,
hereafter called Employer or Company, is a Michigan
corporation with its sole office and place of business in
Livonia, Michigan, where it manufactures, sells, and
distributes automotive parts and accessories, and has,
during the calendar year 1975, a representative period,
purchased and received at said location goods and
materials valued in excess of $50,000 directly from points
outside the State of Michigan, and sold and shipped
products valued in excess of $50,000 from said location
directly to points located outside the State of Michigan.
The Employer is now and has been at all times material
herein an employer engaged in commerce within the
meaning of Section 2(6) and (7) of the Act.
11. THE LABOR ORGANIZATION
The complaint alleges, the Respondent Union hereafter
called the Union admits, and I find that it is a labor
organization within the meaning of Section 2(5) of the Act.
IIl. THE ALLEGED UNFAIR LABOR PRACTICE
A. The Facts
I. Contractual provisions
The Employer and the Union have a collective-bargain-
ing agreement2 covering a unit which included 68 employ-
ees at the time of the hearing herein. The agreement
contains article 6, section 5, reading as follows:
Section 5. Stewards shall be granted super-seniority for
all purposes including lay off and rehire and job
preference if such is required by the Local Union.
However, only one (1) Steward shall have super-
seniority for all plant purposes.
Relevant contractual provisions relating to the selection
and duties of stewards are:
Article 9
Stewards
Section 1. The Employer recognizes the right of the
Union to designate job stewards and alternates from
the Employer's seniority list. The authority of job
stewards and alternates so designated by the Union
shall be limited to, and shall not exceed, the following
duties and activities:
2 The effective date of the agreement is September 15, 1973. and the
expiration date is September 15, 1976.
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DECISIONS OF NATIONAL LABOR RELATIONS BOARD
1. the investigation and presentation of grievances
with his Employer or the designated Company repre-
sentative in accordance with the provisions of the
collective bargaining agreement;
2. the collection of dues when authorized by
appropriate Local Union action;
3. the transmission of such messages and informa-
tion which shall originate with, and are authorized by
the Local Union or its officers ... [here follows certain
limitations on transmission not relevant to the instant
case ].
Article 11
Limitations of Authority and Liability
Section 3. The authority of Union stewards shall be
limited to acts or functions which said stewards are
expressly authorized to perform by the Executive Board
of the Local Union.
Article 8
Arbitration and Grievance Procedure
Section 2. (a) Should any grievances, disputes or
complaints arise over the interpretation or application
of the contents of this Agreement, there shall be an
earnest effort on the part of the parties to settle such
promptly through the following steps:
Step 1. By conference between the aggrieved
employee, the shop steward, or both, and the
foreman of his or her department.
Step 2. By conference between the shop
steward and business agent of the Union, and the
superintendent or the personnel manager.
With respect to the filling of the new jobs, the agreement
provides as follows:
Schedule "A"
Article 1
Job Security
Section 4. Seniority shall be plant-wide, providing an
employee is qualified and able to do the job.
Section 9. The Company agrees that whenever
possible all new jobs shall be posted for a period of
twenty-four (24) hours. Employees who have seniority
and ability to learn shall be entitled to such jobs. Any
dispute as to this section shall be mutually agreed upon
between the Company and the Union.
3 Although I found Turner to be an impressive witness making an honest
effort to recount the facts as he knew them, I have discounted speculative
answers and answers to hypothetical and extremely leading questions posed
by counsel as lacking in evidentiary weight.
The collective-bargaining agreement requires union membership as
condition of employment after 31 days of employment. Accordingly, all
employees, except probationers with less than 30 days' employment, would
be eligible to be elected steward.
Section 10. Employees' seniority shall be determined
by their date of hire. A copy of the up-to-date seniority
list shall be made available to Local No. 299.
The contract expressly provides that the length of
vacations be computed on the basis of length of service
from actual hiring date, but also provides that, should more
than one employee apply for the same vacation date, the
employee with seniority will be given preference.
The allocation of overtime originally set forth in the
contract at schedule A, article 4, wages and hours, section
6, in the following words:
The Company agrees to spread overtime work as
equitably as possible, providing the employee is
capable of performing the available work.
Thereafter, on or about January 7, 1974, the Company
and the Union agreed that all overtime work would be
based on plantwide seniority. This agreement was memorial-
ized in a letter from the Union's president to the
Employer's president on January 7, 1974.
2. The testimony
Union Steward Turner testified3 that he has been the
Union's only steward at the Employer's facility since he
was elected in 1962, that this election was conducted in
accordance with union rules governing the selection of
stewards, that all three candidates were selected by the
employees, that it was a secret-ballot election, and that to
be elected a steward an employee has to be a union
member.4
Turner is third in plantwide seniority and first in
seniority in his job classification by virtue of his hire date,
and there is no evidence that he has personally derived any
preference by virtue of the "super-seniority" clause that he
would not have enjoyed by reason of his normal seniority
rights.
It appears from Turner's testimony that it is the
Employer's policy to call him in to work when it is
necessary to work 3 or 4, or more, employees overtime,5
that overtime is otherwise distributed on the basis of
seniority and qualifications on weekdays and Saturdays,
that he works overtime every weekday and every Saturday,
and that there are normally 12 to 20 employees called in to
work overtime on Saturday. The steward is notified in
advance of the number of employees needed each Satur-
day,6 and he checks the names of those called against the
seniority and job classification list to ensure the agreement
is being followed.
Turner has resolved several grievances on the spot on
Saturdays, and estimates that from January 1976 to the
date of the hearing herein he handled from 40 to 60 oral
grievances that were resolved without being reduced to
writing, and 20 or 30 written grievances. This latter
s Turner asserts that if the Charging Party, who was 54th in actual
seniority, were the steward, the Charging Party would be the first employee
called in on Saturday.
6 The record does not reveal how many people work overtime each
weekday.
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PERFECTION AUTOMOTIVE PRODUCTS
estimate encompasses all complaints handled by him,
whether during regular worktime or overtime. Turner was
aware of the superseniority clause in 1962 which has
remained unchanged in succeeding contracts to the
present. He was unable to explain the meaning of "job
preference," apparently because it has never been ex-
plained to him and he has had no occasion to bid on jobs.
B. Contentions and Conclusions
The complaint alleges that both Respondents violated
the Act "by maintaining in full force and effect" the
disputed clause "as it applies to job preference." At the
hearing General Counsel contended that the "existence of
a superseniority clause for union stewards for purposes
other than lay off and recall, is presumptively invalid." In
her posttrial brief, counsel for the General Counsel argues
that the contractual provision "allows stewards to exercise
super-seniority for purposes of overtime and job prefer-
ence," and is therefore "presumptively invalid." The
argument continues that, even if overtime for stewards is
justified, there is no evidence of justification for supersen-
iority in job preference, and that the term "job preference"
does not refer to overtime.
The Respondent Union concedes that the superseniority
clause is presumptively illegal, but argues that its existence
is justified by the necessity of ensuring the steward's
continued presence on the job during overtime periods to
further the effective administration of the collective-bar-
gaining agreement by prompt, on-the-spot resolution of
disputes arising thereunder and the saving of both time and
money by the resulting avoidance of formal use of the
grievance procedure. In sum, the thrust of the Respondent
Union's argument appears to be that the term "job
preference" refers to the right to come in during overtime
hours, which is justifiable because of the above-described
need for a steward on the job at all times.
Both the General Counsel and the Union rely on
Dairylea ' to support their positions.
In considering the evidence and the arguments I have
kept in mind that the circumstances of this case are unique
in that Steward Turner's normal, earned seniority is
sufficient that he, personally, appears to have derived no
particular benefit. This issue, however, is not whether
Turner himself is receiving a benefit from the superseniori-
ty clause, but whether or not there has been justification
shown for the presumptively invalid clause.
The rule to be followed in evaluating the merit of
General Counsel's affirmative case and the Respondent's
defenses thereto is "that super seniority clauses which are
not on their face limited to layoff and recall are presump-
tively unlawful, and that the burden of rebutting that
presumption (i.e., establishing justification) rests on the
shoulders of the party asserting their legality." The clause
in question in this case is therefore presumptively unlawful
because the steward is specifically granted superseniority
for purposes of job preference. This presumption has not
T Dairylea Cooperative Inc., 219 NLRB 656 (1975).
8 Dairylea. supra at 658.
9 Schedule A. art. 1, job security. refers to job tenure (not overtime
security), posting of "new jobs," and entitlement to "such jobs." Schedule B,
part 1, shop rules, speaks of employees' "respective jobs." The general safety
been rebutted. The only effort to justify this grant is the
attempt of the Respondent Union to equate "overtime
preference" with "job preference." Apart from the fact that
this argument does violence to the English language, the
contract itself uses the term "job" to refer to an employee's
work description or classification 9 and specifically refers to
overtime as "overtime." Furthermore, the title of "job
steward" clearly does not mean "overtime steward."
Although I am inclined to agree that in the peculiar
circumstances of this case superseniority for overtime
purposes might be justifiable, I cannot conclude that there
has been any justification shown for the grant of job
preference. Furthermore, the clause literally grants super-
seniority to stewards for all purposes to be exercised at the
discretion of the Respondent Union when it deems such
exercise to be required. As I read the clause, it is
mandatory that stewards have superseniority for all
purposes, and I find that the enumeration of some of the
purposes included therein does not detract from that
mandate. The steward has, therefore, the broadest possible
grant, as a matter of right, to invoke superseniority in each
and every instance related to his or her employment where
seniority is a factor whenever the Respondent Union
determines that such invocation is required. The Respon-
dents have proffered no evidence, other than that adduced
relating to overtime, to meet the test of justification raised
by the plain language of the clause nor has it been shown
that the superseniority clause means something other than
what it says. That Turner may never have himself taken
advantage of the superseniority grant is irrelevant. It is the
inherent tendency of such clauses to discriminate against
employees for union-related reasons and thus restrain and
coerce them in the exercise of their Section 7 rights. °
Accordingly, I conclude and find that the superseniority
provision of the collective-bargaining agreement between
the Employer and the Respondent Union discussed above
is presumptively unlawful, and that the presumption of
illegality has not been rebutted. Therefore, the Respondent
Union by maintaining this clause in full force and effect
has violated Section 8(bXIXA) and (2) of the Act, and the
Respondent Employer by maintaining this clause in full
force and effect has violated Section 8(aX)(1) and (3) of the
Act.
IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES
UPON COMMERCE
The activities of the Respondents set forth above,
occurring in connection with Respondent Employer's
operations described above, have a close, intimate, and
substantial relationship to trade, traffic, and commerce
among the several States and tend to lead to labor disputes
burdening and obstructing commerce and the free flow of
commerce.
rules refers to "jobs considered hazardous" and "job areas" The substitu-
tion of the word "overtime" for the words "job" or "jobs" would make all
these sections of the agreement ridiculous on their face.
i' Dairylea, supra at 658.
693
DECISIONS OF NATIONAL LABOR RELATIONS BOARD
CONCLUSIONS OF LAW
1. Respondent Employer is an employer within the
meaning of Section 2(2) of the Act, engaged in commerce
within the meaning of Section 2(6) and (7) of the Act.
2. Respondent Union is a labor organization within the
meaning of Section 2(5) of the Act.
3. By maintaining in full force and effect a seniority
clause in their collective-bargaining agreement according
union stewards superseniority for terms and conditions of
employment not limited to layoff and recall, Respondent
Employer and Respondent Union have engaged in, and are
engaging in, unfair labor practices within the meaning of
Section 8(a)(l) and (3) and Section 8(bXIXA) and (2) of the
Act, respectively.
4. The foregoing unfair labor practices are unfair labor
practices affecting commerce within the meaning of
Section 2(6) and (7) of the Act.
THE REMEDY
Having found that Respondents have engaged in certain
unfair labor practices, I shall recommend that they be
ordered to cease and desist therefrom, and take certain
affirmative action to effectuate the policies of the Act.
I have found that the steward superseniority clause here
in dispute is unlawful and shall therefore recommend that
the Respondents be ordered to cease and desist from
maintaining said clause in full force and effect, except to
the extent it grants stewards superseniority in layoff and
recall.
I shall further recommend that the Respondent Employ-
er be ordered to cease and desist in any like or related
manner from interfering with, restraining, or coercing its
employees in the exercise of rights guaranteed by Section 7
of the Act, and that the Respondent Union be ordered to
cease and desist from restraining or coercing employees it
represents in their exercise of the same rights.
Upon the foregoing findings of fact, conclusions of law,
and upon the entire record, and pursuant to Section 10(c)
of the Act, I hereby issue the following recommended:
ORDER
A. Respondent Employer, Perfection Automotive
Products Corporation, Livonia, Michigan, its officers,
agents, successors, and assigns, shall:
1. Cease and desist from:
(a) Maintaining, enforcing, or otherwise giving effect to
those collective-bargaining provisions with Respondent
Union, Local 299, International Brotherhood of Teamsters,
Chauffeurs, Warehousemen and Helpers of America,
according union stewards superseniority with respect to
terms and conditions of employment other than layoff and
recall.
(b) In any like or related manner interfering with,
restraining, or coercing employees in the exercise of their
rights protected by Section 7 of the Act.
2. Take the following affirmative action necessary to
effectuate the policies of the Act:
(a) Post at its establishment at Livonia, Michigan, copies
of the attached notices marked "Appendix A" and
"Appendix B." 12 Copies of said notices, on forms provided
by the Regional Director for Region 7, after being duly
signed respectively by Respondent Employer's and Re-
spondent Union's representatives, shall be posted by the
Respondent Employer immediately upon receipt thereof,
and be maintained by it for 60 consecutive days thereafter,
in conspicuous places, including all places where notices to
employees are customarily posted. Reasonable steps shall
be taken by Respondent Employer to insure that said
notices are not altered, defaced, or covered by any other
material.
(b) Notify the Regional Director for Region 7, in writing,
within 20 days from the date of this Order, what steps the
Respondent Employer has taken to comply herewith.
B. Respondent Union, Local 299, International Broth-
erhood of Teamsters, Chauffeurs, Warehousemen and
Helpers of America, its officers, agents, and representa-
tives, shall:
1. Cease and desist from:
(a) Maintaining, enforcing, or otherwise giving effect to
those clauses in its collective-bargaining agreements with
Respondent Employer, Perfection Automotive Products
Corporation, according union stewards superseniority with
respect to terms and conditions of employment other than
layoff and recall.
(b) Causing or attempting to cause Respondent Employ-
er to discriminate against employees in violation of Section
8(aX3) of the Act.
(c) In any like or related manner restraining or coercing
the employees of Respondent Employer in the exercise of
their rights protected by Section 7 of the Act.
(2) Take the following affirmative action necessary to
effectuate the policies of the Act:
(a) Post at its office and meeting halls used by or
frequented by its members and employees it represents at
Respondent Employer's Livonia facility copes of the
attached notice marked "Appendix B."'3 Copies of said
notice, on forms provided by the Regional Director for
Region 7 shall be posted by Respondent Union after being
duly signed by Respondent Union's representatives, imme-
diately upon receipt thereof. The foregoing notice shall be
maintained by the Respondent Union for 60 consecutive
days after posting in conspicuous places where notices to
members are customarily posted. Reasonable steps shall be
taken by Respondent Union to insure that the notices are
not altered, defaced, or covered by any other material.
(b) Notify the Regional Director for Region 7, in writing,
within 20 days from the date of this Order, what steps the
Respondent Union has taken to comply herewith.
I" In the event no exceptions are filed as provided by Sec. 102.46 of the
Rules and Regulations of the National Labor Relations Board, the findings,
conclusions, and recommended Order herein shall, as provided in Sec.
102.48 of the Rules and Regulations, be adopted by the Board and become
its findings, conclusions, and Order, and all objections thereto shall be
deemed waived for all purposes.
12 In the event that this Order is enforced by a Judgment of a United
States Court of Appeals, the words in the notice reading "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."
13 See fn. 12, supra.
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PERFECTION AUTOMOTIVE PRODUCTS
APPENDIX A
NOTICE To EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
WE WILL NOT maintain and enforce any agreement
with Local 299, International Brotherhood of Team-
sters, Chauffeurs, Warehousemen and Helpers of
America, giving union stewards top seniority no matter
what their length of employment with respect to their
selection for and the assignment to them of contract
benefits or other terms and conditions of employment
except for layoff and recall.
WE WILL NOT in any like or related manner interfere
with, restrain, or coerce employees in the exercise of
their rights protected by Section 7 of the Act.
PERFECTION AUTOMOTIVE
PRODUCTS CORPORATION
APPENDIX B
NOTICE To EMPLOYEES AND MEMBERS
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
WE WILL NOT maintain and enforce any agreement
with Perfection Automotive Products Corporation,
giving our stewards top seniority, with respect to their
selection for, and assignment of, contract benefits or
other terms and conditions of employment except for
layoff and recall or where necessary to perform the
functions of steward.
WE WILL NOT in any like or related manner restrain
or coerce employees in the exercise of their rights
protected by Section 7 of the Act.
LOCAL 299, INTERNATIONAL
BROTHERHOOD OF
TEAMSTERS, CHAUFFEURS,
WAREHOUSEMEN AND
HELPERS OF AMERICA
695