Auciello Iron Works, Inc. v. NLRB, 517 U.S. 781 (1996)

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certiorari to the united states court of appeals for the first circuit

No. 95-668. Argued April 22, 1996—Decided June 3, 1996

The day after petitioner Auciello Iron Works's outstanding contract offer was accepted by its employees' collective-bargaining representative (Union), Auciello disavowed the agreement because of its good-faith doubt, based on knowledge acquired before the offer's acceptance, that a majority of its employees supported the Union. The National Labor Relations Board ruled, inter alia, that Auciello's withdrawal from it was an unfair labor practice in violation of the National Labor Relations Act and ordered that the agreement be reduced to a formal written instrument. The First Circuit enforced the order as reasonable.

Held: The Board reasonably concluded that an employer commits an unfair labor practice when it disavows a collective-bargaining agreement because of a good-faith doubt about a union's majority status at the time the contract was made, when the doubt arises from facts known to the employer before the union accepted its contract offer. Pp. 785-792. (a) In its efforts to achieve the Act's object of industrial peace and stability fostered by collective-bargaining relationships, see, e. g., Fall River Dyeing & Finishing Corp. v. NLRB, 482 U. S. 27, 38, the Board has held that a union is entitled to, inter alia, a conclusive presumption of majority status during a collective-bargaining agreement's term, up to three years, see, e. g., NLRB v. Burns Int'l Security Services, Inc., 406 U. S. 272, 290, n. 12. Upon the contract's expiration, the employer may rebut the presumption of majority status by showing that it has a good-faith doubt, founded on a sufficient objective basis, of the union's majority support. NLRB v. Curtin Matheson Scientific, Inc., 494 U. S. 775, 778. Auciello's assertion that an employer may raise the latter defense even after a contract period has apparently begun to run upon a union's acceptance of an outstanding offer is rejected. Pp. 785-787. (b) The same need for repose that first prompted the Board to adopt the rule presuming a union's majority status during its collective-bargaining agreement's term also led the Board in this case to rule out an exception for the benefit of an employer with doubts arising from facts antedating the contract. The Board's judgment in the matter is entitled to prevail. Auciello's argument for case-by-case determinations of the appropriate time for asserting a good-faith doubt in place of


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