American Federation of State, County & Municipal Employees, Council 75, Local 2043 v. City of Lebanon

The City of Lebanon seeks judicial review of an order of the Employment Relations Board (the board) in which the board concluded that the city committed an unfair labor practice against respondent (the union), in violation of ORS 243.672(l)(a) and (b),1 when Margaret Campbell, a city councilor, wrote a letter criticizing unions and sent it to a local newspaper. We review the board’s order for errors of law pursuant to ORS 183.482(8), and we reverse.

The following facts are either taken from the board’s factual findings or stipulated to by the parties. According to the City of Lebanon Charter…