Source: cases/29usc158/f3d-925-1272-directsat.case
Case source: https://www.neochart.com/catalog/cases/f3d/volume_925/1272_01/index.html
That duty encompasses a responsibility "to provide relevant information needed by a labor union for the proper performance of its duties as the employees' bargaining representative."
The Union thus must demonstrate "a reasonable belief, supported by objective evidence," that the information in the redacted portions of the agreement is relevant to the performance of its duties as the bargaining representative.
The Board reasonably concluded that DirectSat's bargaining proposal rendered the entire agreement relevant.
The company's contention that only portions of the agreement were relevant is belied by the proposal's own reference to the agreement as a whole.
casedsl 1.2 # author: Flash3 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /f3d/925/1272-01 name Directsat U.S. LLC v. Nat'l Labor Relations Bd. cite 925 F.3d 1272 (2019) court Court of Appeals of the District of Columbia date 2019-06-07 url catalog/cases/f3d/volume_925/1272_01/index.html source ir/caselaw/f3d_925.jsonl sha1=091fc6c4a4624ec3f2ce006abe3494fd7059ae9a chars=15840 opinion op : majority by Srinivasan @0..15840 controlling party p1 : DirectSat USA, LLC count c1 : § 8(a)(5) refusal to disclose relevant bargaining information law 29usc158 role applied posture petition for review and cross-application for enforcement of NLRB order finding employer violated § 8(a)(5) by refusing to disclose relevant agreement; enforcement granted and petition denied result claimant-won element refusal-to-bargain : satisfied [proved] party p1 count c1 route information-request pattern employer's bargaining proposal defines unit work by reference to a third-party agreement, then employer supplies only a redacted copy rule @11609..11791 | That duty encompasses a responsibility "to provide relevant information needed by a labor union for the proper performance of its duties as the employees' bargaining representative." rule @12048..12277 | The Union thus must demonstrate "a reasonable belief, supported by objective evidence," that the information in the redacted portions of the agreement is relevant to the performance of its duties as the bargaining representative. fact @1924..2223 [supports] | DirectSat submitted a New Product Lines proposal containing the following term: "In the event [DirectSat] is engaged with respect to products or services other than those provided pursuant to its Home Service Provider agreement with DirecTV ... , such work shall not be deemed bargaining unit work." fact @2759..2886 [supports] | In the ensuing months, the Union repeatedly demanded the full Home Service Provider agreement and DirectSat repeatedly refused. fact @2536..2692 [cuts-against] | Two weeks later, DirectSat responded with a heavily redacted copy of the Home Service Provider agreement, which it described as "relevant to scope of work." held @975..1082 | The Board reasonably concluded that DirectSat's bargaining proposal rendered the entire agreement relevant. held @12893..13038 | The company's contention that only portions of the agreement were relevant is belied by the proposal's own reference to the agreement as a whole. gloss D.C. Circuit enforces the Board's order: by defining bargaining-unit work by reference to its whole agreement with DirecTV, the employer made the whole agreement relevant, and withholding the unredacted copy breached the § 8(a)(5) duty to furnish information. The case went to the ALJ on a stipulated record. gloss Not recorded here: the denial of DirecTV's untimely motion to intervene and the due-process objection (procedural, not elements of § 158(a)).