United States Court of Appeals for the Sixth Circuit · 1988-03-02
29usc158: author: Astra4 · not independently reviewed
Case and law context
Role: applied; posture: Board enforcement proceeding over requested identities of union officers seeking supervisory posts; disclosure/privacy and relevance objections resolved.; result: claimant-won; claim: (a)
Uncertainty
None recorded
Misfit
Privacy Act and loyal-representation conflict questions are companion doctrines absent from the small LAW vocabulary; they qualify this refusal-to-bargain variant rather than becoming universal extra elements.
Result is from the perspective of the General Counsel or charging party asserting the employer unfair labor practice, not from the employer-petitioner’s appellate position.
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 17
| Case | Covered employer | Covered employee and applicable retained status | Section 7 protected rights | Interference, restraint or coercion | Noncoercive expression under §8(c) | Narrow insignia-restriction justification |
|---|---|---|---|---|---|---|
| National Labor Relations Board v. United States Postal Service — 841 F.2d 141 (1988) · United States Court of Appeals for the Sixth Circuit · 1988 (29usc158: author: Astra4 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 17
| Case | Domination, interference or support of a labor organization | Working-hours conference proviso | Conditional building-and-construction agreement allowance | Employment discrimination | Union-related discriminatory motivation | Same action absent unlawful motive |
|---|---|---|---|---|---|---|
| National Labor Relations Board v. United States Postal Service — 841 F.2d 141 (1988) · United States Court of Appeals for the Sixth Circuit · 1988 (29usc158: author: Astra4 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 13–17 of 17
| Case | Conditional union-security proviso | Filed charges or given testimony | Discharge or other discrimination for Board participation | Employees collective-bargaining representative | Alternative breaches of applicable collective-bargaining duties |
|---|---|---|---|---|---|
| National Labor Relations Board v. United States Postal Service — 841 F.2d 141 (1988) · United States Court of Appeals for the Sixth Circuit · 1988 (29usc158: author: Astra4 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| National Labor Relations Board v. United States Postal Service — 841 F.2d 141 (1988) · United States Court of Appeals for the Sixth Circuit · 1988 — satisfied · law (29usc158: author: Astra4 · not independently reviewed) | Alternative breaches of applicable collective-bargaining duties | satisfied Counted merits instance applied / merits basis: law; claim: (a); theory: information disclosure; subject: theory=information disclosure The duty is applied to specific relevant information; relevance and the employer’s privacy interests are balanced, not assumed from every union request. | information/refusal-to-identify-potentially-conflicted-representatives | Gene Cole, the Detroit MSC’s Postmaster, responded by letter and refused to provide the union with the information until its relevance to the collective bargaining process was explained.Source: docroot/ir/caselaw/f2d_841.jsonl#/f2d/841/0141-01; Unicode character offsets [6651:6837] (end exclusive); SHA-256 cdb9c687b3fe037ff5d885f593b297e4e0d36e897a91fa18b5affd0d1b33cf70.Generally, an employer’s duty to bargain collectively established in § 8(a)(5) of the National Labor Relations Act , obligates it to provide a labor union with relevant information necessary for the proper performance of the union’s duties as the employees’ bargaining representative.Source: docroot/ir/caselaw/f2d_841.jsonl#/f2d/841/0141-01; Unicode character offsets [8875:9159] (end exclusive); SHA-256 cdb9c687b3fe037ff5d885f593b297e4e0d36e897a91fa18b5affd0d1b33cf70.Therefore, we find that the union’s interest in the disclosure of the information is relevant to its duty to provide loyal representation and is not outweighed by the Postal Service's interest.Source: docroot/ir/caselaw/f2d_841.jsonl#/f2d/841/0141-01; Unicode character offsets [17562:17755] (end exclusive); SHA-256 cdb9c687b3fe037ff5d885f593b297e4e0d36e897a91fa18b5affd0d1b33cf70. |