Court of Appeals of the District of Columbia · 2019-06-07
29usc158: author: Flash3 · QA: PASS (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
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; claim:
Uncertainty
None recorded
Misfit
None recorded
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 |
|---|---|---|---|---|---|---|
| Directsat U.S. LLC v. Nat'l Labor Relations Bd. — 925 F.3d 1272 (2019) · Court of Appeals of the District of Columbia · 2019 (29usc158: author: Flash3 · QA: PASS (Fable, neov2/cases/TRIAGE-Flash.md)) | · 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 |
|---|---|---|---|---|---|---|
| Directsat U.S. LLC v. Nat'l Labor Relations Bd. — 925 F.3d 1272 (2019) · Court of Appeals of the District of Columbia · 2019 (29usc158: author: Flash3 · QA: PASS (Fable, neov2/cases/TRIAGE-Flash.md)) | · 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 |
|---|---|---|---|---|---|
| Directsat U.S. LLC v. Nat'l Labor Relations Bd. — 925 F.3d 1272 (2019) · Court of Appeals of the District of Columbia · 2019 (29usc158: author: Flash3 · QA: PASS (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Directsat U.S. LLC v. Nat'l Labor Relations Bd. — 925 F.3d 1272 (2019) · Court of Appeals of the District of Columbia · 2019 — satisfied · proved (29usc158: author: Flash3 · QA: PASS (Fable, neov2/cases/TRIAGE-Flash.md)) | Alternative breaches of applicable collective-bargaining duties | satisfied Counted merits instance applied / merits basis: proved; party: DirectSat USA, LLC; count: § 8(a)(5) refusal to disclose relevant bargaining information; subject: party=DirectSat USA, LLC; count=§ 8(a)(5) refusal to disclose relevant bargaining information 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. Not recorded here: the denial of DirecTV's untimely motion to intervene and the due-process objection (procedural, not elements of § 158(a)). | employer's bargaining proposal defines unit work by reference to a third-party agreement, then employer supplies only a redacted copy | 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."Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [11609:11791] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01.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.Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [12048:12277] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01.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."Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [1924:2223] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01.In the ensuing months, the Union repeatedly demanded the full Home Service Provider agreement and DirectSat repeatedly refused.Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [2759:2886] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01.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."Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [2536:2692] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01.The Board reasonably concluded that DirectSat's bargaining proposal rendered the entire agreement relevant.Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [975:1082] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01.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.Source: docroot/ir/caselaw/f3d_925.jsonl#/f3d/925/1272-01; Unicode character offsets [12893:13038] (end exclusive); SHA-256 e3c7ae44fd8beeb862eb2695b0a3ac38f9ddf2ef1f82deece4b6c30c1c0aea01. |