United States Department of the Interior v. Federal Labor Relations Authority

Opinion for the Court filed by Circuit Judge EDWARDS.

HARRY T. EDWARDS, Circuit Judge:

In 1990, the Bureau of Reclamation (“Bureau”), a division of the Department of the Interior (“DOI”), unilaterally removed certain supervisors from two bargaining units that historically had been “mixed,” i.e., consisting of supervisory and non-supervisory personnel. The unions representing the supervisors filed grievances, charging that DOI’s failure to give notice of its proposed changes in the composition of the bargaining units violated the governing collective bargaining agreements. The parties submitted…