National Labor Relations Board v. Curwood Inc.

WILLIAMS, Circuit Judge.

An employer who learns its employees are contemplating unionization need not remain silent. It must proceed with caution, however, lest it violate the National Labor Relations Act (“NLRA”). In this case, Curwood, Inc. attempted to counter a union campaign in part by promising improvements in pension benefits to employees in the voting unit. It also announced benefits to a small group of employees that were excluded from the unit. The National Labor Relations Board (“Board”) ruled that these actions constituted several unfair labor practices, and the Board now seeks to…