The American Can Co.

National Labor Relations Board - Board Decisions

Aug 30, 1979

244 N.L.R.B. 736 (N.L.R.B. 1979)

I)E(ISIONS OF NATIONAL LABOR RELATIONS BOARD
The American Can Company and Stanley H. Egan
and I)onald R. Egan
United Steelworkers of America and Local 5490 of the
United Steelworkers of America and Stanley H.
Egan and Donald R. Egan. Cases 27-CA 4945 and
27 CB- 1032
August 30, 1979
SUPPLEMENTAL DECISION AND ORDER
On April 5, 1978, the National Labor Relations
Board issued its Decision and Order' in this proceed-
ing finding that the superseniority provision of the
collective-bargaining agreement was lawful on its
face, and that application of the provision was not
unlawful. Accordingly, the Board ordered that the
complaint be dismissed in its entirety. On May 2,
1978, Stanley H. Egan and Donald R. Egan, the indi-
vidual Charging Parties, filed a petition for review
with the United States Court of Appeals for the
Tenth Circuit. After announcement to the parties the
Board, on September 26, 1978, filed a motion with the
court to withdraw the record herein to permit it to
reconsider its Decision and Order. On November 6,
1978, the Board notified the parties that the process-
ing had been remanded for reconsideration and in-
vited them to submit briefs. Thereafter, the Charging
Parties, Respondent Employer, and the General
Counsel filed briefs on remand.
Upon the entire record in this proceeding, includ-
ing the briefs of the parties, the Board makes the fol-
lowing:
FINDINGS AND CONCLUSIONS
A. The Issue
At issue herein is whether Respondent Employer
and Respondent Unions violated Section 8(a)(1) and
(3) and Section 8(b)(I)(A) and (2), respectively, by
applying the superseniority provision of the collec-
tive-bargaining agreement to permit local union offi-
cers, including a guard (i.e., a position similar to ones
usually titled "Sergeant-at-Arms") and a trustee, to
retain their employment in the face of layoffs of em-
ployees with greater plant seniority.
B. Facts
The pertinent facts are not in dispute. The Em-
ployer and the International Union were parties to a
collective-bargaining agreement covering various of
1235 NLRB 704.
the Employer's plants, including the Denver, Colo-
rado, plant involved herein. Local 5490 represented
the production and maintenance unit employees at
the Denver plant. In October 1975 the Employer told
the union that it was going to cease production at the
Denver plant as of December 5, 1975.2 Accordingly,
on that day the Employer laid off all but 11 of its unit
employees, who were retained to dismantle, crate,
store, and ship machinery. Subsequently. the Em-
ployer made additional layoffs and recalls.
The collective-bargaining agreement between the
Union and the Employer provided that in the event
of layoffs unit employees with the greater seniority
were to be retained provided that they could perform
the work. The agreement also provided that superse-
niority would "apply to a total of not more than ten
local union officers and grievance committeemen
who, notwithstanding their positions on the seniority
roster, shall have preferential seniority in case of lay-
off or recall." Pursuant to the agreement a seniority
roster had been posted in the plant, and the Union
had advised the Employer of the 10 union officers and
committeemen for whom it claimed superseniority
status.'
The parties stipulated that of the 11 employees re-
tained on December 5, 1975, C. E. Bugh and D. R.
Howard were retained on the basis of superseniority.
Bugh was the Local Union's treasurer and a griev-
ance committeeman. (A grievance committeeman
served as a steward at the plant.) Howard was a
trustee for the Local. The union constitution de-
scribes a trustee's duties as "to have charge of the hall
and all property of the Local Union ... and perform
such other duties as the Local Union may require."
The record does not show that Howard had any other
duties as trustee.4
The Administrative Law Judge found that C.
Thompson, a trustee, was also retained because of his
superseniority. Although Thompson was on the
superseniority list and was only 25th in plant senior-
ity, the parties did not stipulate and the General
Counsel did not argue in its brief to the Administra-
tive Law Judge that he was retained because of super-
seniority. In addition, in their brief on recall the
Charging Parties state, "Thompson had a secondary
basis for his recall based upon his specific job qualifi-
cations." There is no direct evidence why Thompson
was retained. Accordingly, we find that the record
2 Pursuant to its usual practice in plant closures the International ap-
pointed an administrator over the affairs of Local 5490.
3 Employee seniority ranking and the Union's superseniority claims are
detailed in the Administrative Law Judge's Decision, attached to our origi-
nal Decision and Order herein.
I Howard was also chairman of the health and safety committee. This.
however, was not the result of his being a trustee and was not the reason he
was given superseniority. In addition. the Administrative Law Judge found,
and the record supports his finding, that the testimony that Howard was
active in this role in the period in question was not convincing
244 NLRB No. 78
736
AMERICAN CAN COMPANY
will not support the finding that Thompson was re-
tained on the basis of his superseniority as a union
officer.
The parties stipulated that W. S. Miller. grievance
committee chairman, and S. Schneider, a guard, were
recalled on January 5, 1976. on the basis of superse-
niority. The Union's constitution describes the duties
of a guard as "to take charge of the door and see that
no one enters who is not entitled to do so." Schneider
performed no other official duties for the Union.
On February 13 and 20, 1976, there were general
layoffs. Thereafter, as stipulated by the parties, How-
ard was recalled on May 25, 1976, on the basis of
superseniority. He was laid off on September 2, 1976.
C. Discussion
The record shows that Howard and Schneider were
the only employees retained or recalled solely on the
basis of their superseniority as union officers, namely,
trustee and guard, respectively The record further
shows that other employees who were not retained or
recalled had greater plant seniority than Howard,
who was 14th on the list, and Schneider, who was 22d
on the list, and who would have been retained or re-
called but for the superseniority afforded Howard
and Schneider. 6
In Dairylea Cooperative, Inc., 219 NLRB 656
(1975), enfd. 531 F.2d 1162 (2d Cir. 1976), the Board
majority held that superseniority clauses which oper-
ate to keep a union steward on the job are permissible
because the steward's functions benefit all unit em-
ployees. he governing considerations were stated in
Dairylea at 658:
[I]n view of the inherent tendency of super se-
niority clauses to discriminate against employees
for union-related reasons . . . we do find 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.
Dairylea, however, applied only to superseniority af-
forded to union stewards. In United Electrical, Radio
and Machine Workers of America, Local 623 (Limpco
Mfg., Inc.), 230 NLRB 406 (1977), enfd. sub nom.
Anna M. D'Amico v. N.L.R.B., 582 F.2d 820, 824 (3d
5 Other officers were retained but not solely because they were officers.
Some were at the top of the seniority list, some were also grievance commit-
teemen (stewards), and some were not shown to have been retained because
they were officers (as with Thompson).
For example, the individual Charging Parties, Stanley H. Egan and Don-
ald R. Egan, were 9th and 10th, respectively, on the seniority list and were
apparently discriminated against. Actual determination of who would have
been recalled or retained but for the superseniority afforded Howard and
Schneider is to be determined in the compliance stage of this proceeding.
Cir. 1978), the Board majority held that the Dairylea
presumption that superseniority protection for stew-
ards is lawful because it "furthers the effective admin-
istration of the bargaining agreements on the plant
level" applies to union officers because they play an
important role in contract administration. In Otis
Elevator Comnpanl, 231 NLRB 1128 (1977), the Board
majority held that union officers may lawfully be
given superseniority because they generally contrib-
ute, in their official capacities. to the ability of the
union to represent the unit effectively and efficiently.
The panel majority issuing the Board's Decision
and Order in this proceeding. relying in part on the
above-cited cases, found that the superseniority pro-
vision involved herein was presumptively lawful be-
cause it covered only union officers and committee-
men, and that the Board would not question a union's
decision as to which officers aid the union in eflec-
tively representing the unit. Subsequent to that deci-
sion the Third Circuit issued Anna M. D'.4nico v.
N.L.R.B., supra. In doing so the court stated that the
respondent "was obligated to produce credible proof
that the individual in question was officially assigned
duties which helped to implement the collective bar-
gaining agreement in a meaningful way. An) less
rigid interpretation of the Board's ruling would leave
substantial room to dilute the statutory neutrality
principle without the requisite collective bargaining
justification" (582 F.2d 825).
Upon reflection of the issues involved herein and
consideration of the D'Amico decision the Board de-
cided to reconsider sua sponte its earlier Decision and
Order herein. As can be seen from the above-cited
cases the Board Members have widely divergent
views on Dain'lea issues, particularly on that issue
involved herein. Thus, this Supplemental Decision
and Order is based on an aggregate majority as fol-
lows: Chairman Fanning and Member Truesdale do
not agree with the restrictions placed on supersenior-
ity by Dairylea and its progeny (see their dissent
herein): Members Jenkins and Penello would not per-
mit union officers to benefit from superseniority ex-
cept when the officers also serve as stewards or other-
wise engage in administration of the contract at the
place and during the hours of their employment (see
their concurrence herein); and Member Murphy ad-
heres to Dairylea and Limpco. supra, but finds that the
General Counsel has rebutted the presumption that
the union officers here involved were lawfully af-
forded superseniority by showing that Howard and
Schneider are not engaged in contract administration
(see her separate concurrence herein). Thus, the ma-
jority of the Board finds that Respondents violated
the Act as alleged in their application of the superse-
niority provision in question to trustee Howard and
guard Schneider.
737
DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Upon the aggregate majority outlined above the
Board makes the following:
CONCLUSIONS OF LAW
I. The Employer was at all material times an em-
ployer engaged in commerce, and the Unions were
labor organizations within the meaning of the Act.
2. United Steelworkers of America and Local 5490
of the United Steelworkers of America violated Sec-
tion 8(b)(1)(A) and (2) of the Act by requesting the
Employer to retain or recall trustee Howard and
guard Schneider under the superseniority provision of
the applicable collective-bargaining agreement while
senior employees holding superior contractual reten-
tion and recall rights were denied retention and recall
inasmuch as the union duties of those officers do not
involve the representation of unit employees in mat-
ters involving the administration of the agreement or
grievance processing.
3. The American Can Company violated Section
8(a)(1) and (3) of the Act by complying with the
above-described request of the Unions.
4. The above-described unfair labor practices af-
fect commerce within the meaning of the Act.
THE REMEDY
Having found that Respondents violated the Act
by effecting a discriminatorily unlawful application of
their superseniority provision, we shall order them to
cease and desist from any such discriminatory appli-
cation. Because trustee Howard and guard Schneider
were retained or recalled pursuant to an unlawful ap-
plication of the superseniority provision of the collec-
tive-bargaining agreement in derogation of the rights
of senior employees to contractual retention and re-
call rights, it shall be ordered that Respondent
Unions and Respondent Employer make whole any
wage losses suffered by those senior employees who
would have been retained or recalled between De-
cember 5, 1975, and September 2, 1976, but for the
unlawful retention and recall of Howard and Schnei-
der, less any net earnings, such employees would have
received in the periods they would have been em-
ployed. The lost wages and interest thereon shall be
computed in the manner presribed in F. W. Wool-
worth Company, 90 NLRB 289 (1950), and Florida
Steel Corporation, 231 NLRB 651 (1977).7
ORDER
Pursuant to the provisions of Section 10(c) of the
National Labor Relations Act, as amended, the Na-
tional Labor Relations Board hereby orders that:
See, generally, Isis Plumbing a Heating Co., 138 NLRB 716 (1962).
A. Respondent, The American Can Company,
Denver, Colorado, its officers, agents, successors, and
assigns, shall:
1. Cease and desist from:
(a) Permitting, in any layoffs or recalls within units
covered by agreements between The American Can
Company and United Steelworkers of America and
its affiliated local unions, superseniority to be invoked
for other than a reasonable number of local union
officers whose duties involve the administration of the
agreement or the processing of grievances whenever
such invocation or permission results in the displace-
ment of unit employees with greater seniority status
under the agreement for purposes of layoff or 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 designed
to effectuate the purposes and policies of the Act:
(a) Make whole those unit employees who would
have been retained or recalled under the agreement
but for the retention or recall of trustee Howard and
guard Schneider between December 5. 1975, and Sep-
tember 2, 1976, at the Employer's Denver, Colorado,
plant in the manner set forth in the section of this
Supplemental Decision and Order entitled "The
Remedy."
(b) Preserve and, upon request, make available to
the Board or its agents, for examination and copying,
all payroll records, social security payment records,
timecards, personnel records and reports, and all
other records necessary to analyze the amount of
backpay due under the terms of this Order.
(c) Post at the plants of the Employer where em-
ployees are covered by national agreements between
the Employer and the United Steelworkers of Amer-
ica copies of the attached notice marked "Appendix
A." 8 Copies of said notice, on forms provided by the
Regional Director for Region 27, after being duly
signed by the Employer's representative, shall be
posted by the 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 the Em-
ployer to insure that said notices are not defaced, al-
tered, or covered by any other material.
(d) Notify the Regional Director for Region 27, in
writing, within 20 days from the date of this Order,
what steps Respondent Employer has taken to com-
ply herewith.
I 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."
738
AMERICAN CAN COMPANY
B. Respondent United Steelworkers of America
and Local 5490 of the United Steelworkers of Amer-
ica, their officers, agents, and representatives, shall:
1. Cease and iesist from:
(a) Invoking, in any layoffs or recalls within units
covered by agreements between The American Can
Company and United Steelworkers of America and
its affiliated local unions, superseniority for other
than a reasonable number of local union officers
whose duties involve the administration of the agree-
ment or the processing of grievances whenever such
invocation results in the displacement of unit employ-
ees with greater seniority status under the agreement
for purposes of layoff and recall.
(b) In any like or related manner restraining or co-
ercing employees in the exercise of their rights pro-
tected by Section (7) of the Act.
2. Take the following affirmative action designed
to effectuate the purposes and policies of the Act:
(a) Make whole those unit employees who would
have been retained or recalled under the agreement
but for the retention or recall of trustee Howard or
guard Schneider between December 5, 1975, and Sep-
tember 2, 1976, at the Employer's Denver, Colorado,
plant in the manner set forth in the section of this
Supplemental Decision and Order entitled "The
Remedy."
(b) Post at the meeting halls of local unions affili-
ated with the United Steelworkers of America which
have members covered by national agreements be-
tween the Employer and the United Steelworkers of
America copies of the attached notice marked "Ap-
pendix."9 Copies of said notice, on forms provided by
the Regional Director for Region 27, after being duly
signed by Respondent Union's representative, shall
be posted by it immediately upon receipt thereof, and
be maintained by it for 60 consecutive days there-
after, in conspicuous places, including all places
where notices to members are customarily posted.
Reasonable steps shall be taken by the Union to in-
sure that said notices are not defaced, altered, or cov-
ered by any other material.
(c) Notify the Regional Director for Region 27, in
writing, within 20 days from the date of this Order,
what steps Respondent Union has taken to comply
herewith.
MEMBERS JENKINS and PENELLO, further concurring:
We agree that this contractual provision herein
which permitted trustee Howard and guard Schneider
to benefit from superseniority is unlawful, not merely
because it applies to union officers who play no role
in the effective and efficient administration of the
contract, but also because it applies to all union offi-
I See fn. 8, supra.
cers without regard to whether they act as stewards.
In our opinion, the contract provision in question is
unlawful on its face.
In Dairylea, supra, the Board held that supersenior-
ity provisions giving benefits to stewards with regard
to layoff and recall are lawful. The Board majority,
however, has expanded Dairylea, in Limpco, supra, in
Otis Elevator, supra, and in this case to include union
officers with those employees who may lawfully bene-
fit from superseniority. We do not agree: see our dis-
sents in Limnpco and Otis Elevator. Superseniority pro-
visions which benefit union officials, be they stewards,
officers, or others, are by their very nature coercive
because they discriminatorily encourage and reward
union participation contrary to the Section 7 right to
refrain from such activity. We recognized, however,
in Dairylea that a steward's processing of grievances
and enforcement of the collective-bargaining agree-
ment on the job offset any restraint on Section 7
rights by the facilitation of unit employees' contrac-
tual rights. Thus, Dainlea found that superseniority
protection with respect to layoff and recall for union
stewards was lawful because its objective was to re-
tain on the job those union officials whose activities
facilitate employee rights and whose presence on the
job is required for the proper performance of this
function.
In our view, permitting union officers who do not
so act as stewards to benefit from superseniority is
contrary to the operative principles of Dairylea. Even
if union officers facilitate employee rights by acting to
effectively and efficiently administer the collective-
bargaining agreement, the proper performance of
such activities does not require the continued pres-
ence of the officers on the job. Thus, at most, union
officers meet only half of the twofold test of Dairvlea.
In contrast, the steward's activities, i.e., the handling
and adjustment of on-the-job grievances, serve to
benefit employees, and are such that the steward's
presence on the job is necessary. Put differently, the
activities of union officers, however they benefit em-
ployees, do not generally involve on-the-job func-
tions, while those of stewards are primarily on-the-job
activities.
In this case the superseniority provision in issue, on
its face and in its application, permits union officers
to benefit merely because of their status as officers
and not because their presence on the job is necessary
for handling grievances. Accordingly, we would find
that the superseniority provision is unlawful on its
face, and that, perforce, application of that provision
to benefit union officers is unlawful.
MEMBER MURPHY, concurring:
As I stated in Union Carbide Corporation Chemical
and Plastics Operations Division, 228 NLRB 1152
739
DECISIONS OF NATIONAL LABOR RELATIONS BOARD
(1977), 1 find presumptively lawful those clauses giv-
ing job retention superseniority-including layoff. re-
call, shift assignment, or retention of the same job or
category of job during incumbency in such position-
for union stewards and officers whose functions re-
late, in general, to furthering the bargaining relation-
ship. I have also stated that the General Counsel has
the burden of proving affirmatively that the applica-
tion of a superseniority clause to a union officer is
invalid. Limpco Mfg., Inc., 230 NLRB 406, 408 (1977).
The Third Circuit, in enforcing Limpco, supra, enid.
sub nom. Anna M. D'Amico v. N.L.R.B., 582 F.2d
820, 825 (1978), found the Board's accommodation
permissible when a proper justification appears. The
court stated that it read the Board's Decision to mean
that "the Union was obligated to produce credible
proof that the individual in question was officially as-
signed duties which helped to implement the collec-
tive bargaining agreement in a meaningful way."
These, then, are the burdens which must be satis-
fied. An examination of the undisputed facts here dis-
closes that the General Counsel has met his initial
burden of showing invalidity in the application of this
clause. The duties of the guards, according to the In-
ternational Union's constitution, are to "take charge
of the door and see that no one enters [a meeting]
who is not entitled to do so." The trustees' duties are
defined as "to have charge of the hall and all property
of the Local Union . . . and perform such other duties
as the Local may require." None of the duties of ei-
ther office, as so specified in the Union's constitution,
relates to the general furthering of the bargaining re-
lationship as set forth by the court. Hence, the duties
of guard and trustee are too remote to justify superse-
niority for such positions. The burden thus shifted to
Respondents to come forward with evidence that
these officers, in fact, do perform functions which re-
late to the "general furthering of the bargaining rela-
tionship." But Respondents have failed to establish
that either trustee Howard or guard Schneider has
any such responsibilities.' 0
Therefore I emphasize that while I find the clause
lawful on itsface, I find that under the facts here Re-
spondents violated the Act by their application of the
superseniority provision to trustee Howard and guard
Schneider. Accordingly, I join in adopting the remedy
set forth in the principal opinion.
CHAIRMAN FANNING and MEMBER TRUESDALE, dis-
senting:
We would dismiss the complaint in its entirety for
10 No evidence was presented with respect to other duties of Schneider.
With respect to Howard, the evidence adduced related to his position as
chairman of the health and safety committee. This, however, was not the
result of his being a trustee and was not the reason that he was given super-
seniority.
the reasons stated in the original Decision and Order
in this proceeding (235 NLRB 704), and because we
do not agree with the restrictions placed on superse-
niority by Dairylea and its progeny. See Chairman
Fanning's dissents in Dairylea and A.P.A. Transport
Corp., 239 NLRB 1407 (1979), and Member Trues-
dale's separate dissent in A.P.A. Transport.
Contractually providing superseniority benefits for
union stewards and officers does not, in our view, in-
terfere with, restrain, or coerce employees in the exer-
cise of their rights but instead serves to benefit the
union, the employer, and the employees. We do not
believe that the remote and contingent benefits of
superseniority associated with service as a steward or
officer have any significant impact on whether an em-
ployee chooses to support a union.
Instead, the only real effect of such provisions is to
encourage and reward service as a union official. Nor
do we believe that rewarding union officials for their
service adversely affects unit employees. To the con-
trary, such rewards serve to benefit all the employees
in the unit. A union can represent unit employees
only through the actions of its officers and stewards.
To encourage quality representation by giving super-
seniority rewards to such officers thus serves the inter-
ests not only of unions and employers but also of all
employees, both members and nonmembers. Thus, in
our view, superseniority for union officials serves the
purpose of effective and efficient representation of
unit employees by the union. For these reasons we
would find that such provisions which are duly nego-
tiated by the parties and contained in their bargaining
agreements are presumptively lawful provided, of
course, that they meet the tests of reasons and good
faith.
The superseniority provision in issue in the instant
proceeding clearly meets these standards. The provi-
sion gives superseniority to a reasonable number of
union officers and grievance committeemen (10) who
contribute, in their official capacities, to the ability of
the union to represent all the employees in the unit
effectively and efficiently. Accordingly, we would find
that the provision in issue is presumptively lawful. A
description of the officers' duties showing no visible
or direct impact by them on contract administration
is not sufficient to rebut the presumption of lawful-
ness. We would not, on the basis of such evidence,
second-guess a union's decision as to which officers
aid the union in effectively representing the unit. To
do otherwise would be contrary to the realities of bar-
gaining, would ignore the often vital indirect impact
on contract administration by apparently low-level
officers, and would put the Employer in the impossi-
ble position of trying to determine to which officials it
740
AMI RICAN ( .\N CO()MI'PANY
can lawt'ull 5 give superseniorit. or these reasons we
would dismiss the complaint in its entirety.
APPENDIX A
No( l: I o EMI'I ()Yil-s
POStItt) BY ORDEI)IR It- IlI
NA I()tNAI. LAB()R R.AIIONS BOARD
An Agency of the United States GCovernmnent
Wi WI.I. NO1 permit any local union affiliated
with the above International Union to invoke
superseniority of such agreements for other than
a reasonable number of local union officers
whose duties involve the administration of such
agreements or the processing of grievances
whenever such permission results in the displace-
ment of unit employees with greater seniority
status under such agreements for purposes of
layoff and recall.
WE Wll. NOT in any like or related manner
interfere with, restrain, or coerce our employees
in the exercise of their rights protected by Sec-
tion 7 of the National Labor Relations Act.
W[ wii.t. make whole for any wage losses, plus
interest. those senior employees suffered who
would have been retained in or recalled to active
employment at our Denver. Colorado. plant be-
tween December 5 1975. and September 2. 1976.
but for the retention and recall of Steelworkers
I.ocal Union 5490 trustee [). R. loward and
guard S. Schneider.
TitI AMi RI('AN ('AN ((), MPAN
APPIN )IX B
T4o11( I() NIIi i)YI I S
POslll) BY OR)DER () it
N'AIIO)NAI AB()R Ril .I i}NS BI)ARI)
An Agenct of the United States (overnnltenl
WI. vt 1i. No)I invoke the superseniorit\ provi-
sion oft such agreements for other than a reatson-
able number ot' Local Union officers whos duties
involve the administration of such agreements or
the processing of grievances whenever such invo-
cation results in the displacement of unit em-
ployees with greater seniority status under such
agreements for purposes of laot' and recall.
WE wnt.. (Nt1 in an, like or related manner
restrain or coerce employees oft' 'he American
Can Company in the exercise oft' their rights pro-
tected by Section 7 of' the National .ahbor Rela-
tions Act.
W}t wt.i. make whole for any wage losses. plus
interest. those senior employees suffered who
would have been retained in or recalled to active
employment at the Denver. Colorado. plant. of'
The American Can Compan, between I)ecem-
her 5. 1975. and September 2. 1976. but for the
retention and recall of Steelworkers ocal Union
5490 trustee I). R. Howard and guard S. Schnei-
der.
U\N II t) S i I:V, O()RKI RS 01 AMIRI( A
741