City of Boston v. Labor Relations Commission

We consider the circumstances under which documents claimed to be confidential may be required to be produced in order to assist a union in evaluating and pursuing a grievance. The failure to produce the documents led to an unfair labor practice proceeding before the Massachusetts Labor Relations Commission (commission). We hold that the employer made a sufficient showing of confidentiality to require the commission to examine the document in camera before the commission *398could conclude that the withholding of the document was an unfair labor practice and require its production to the union.

Fac…