National Labor Relations Board v. International Brotherhood of Electrical Workers, Local 77

The National Labor Relations Board (“NLRB”) petitions for enforcement of its order holding the International Brotherhood of Electrical Workers, Local No. 77 (“Local 77”), in violation of § 8(b)(1)(B) of the National Labor Relations Act (“the Act”), 29 U.S.C. § 158 (b)(l)(B)(1982). Local 77 disciplined two members of the International Brotherhood of Electrical Workers, Local No. 112 (“Local 112”) for knowingly and repeatedly doing work that belonged to Local 77, thereby violating Local 77’s jurisdiction. The disciplined union members were also foremen for Bruce-Cadet, Inc. (“Bruce-Cadet”) Even though Local 77 neither had a collective bargaining relationship with Bruce-Cadet, nor aspired to one, the Board held that Local 77’s actions violated § 8(b)(1)(B). We enforce the Board’s order.

I

Bruce-Cadet, an electrical subcontractor on construction projects, is party to a “Site Stabilization Agreement” (“SSA”) that governs the terms and conditions of employment for all construction work at the Han-ford Nuclear Reservation in the State of Washington. Bruce-Cadet regularly employs members of Local 112 to do electrical work at the Hanford site. Local 112, which has jurisdiction over…