Director of the Division of Employee Relations v. Labor Relations Commission

Suppose the Labor Relations Commission (Commission) has properly found on complaint of a public employer that a union of public employees instigated an *163illegal withholding of services by its members. May the Commission, in issuing a cease and desist order against the union, add an order requiring the parties to submit to arbitration an alleged “hiring freeze” and work assignment by the employer, when arbitration was not applied for under the grievance provision of the collective bargaining agreement, and the Commission has not proceeded with a pending “prohibited practice” complaint against…