Tanforan Park Food Purveyors Council and the Hapsmith Company v. National Labor Relations Board

FERGUSON, Circuit Judge:

Two corporations appeal a bargaining order of the National Labor Relations Board *1360(“NLRB”). They claim that they were erroneously determined to be joint employers and erroneously denied a new election or evidentiary hearing. We remand for consideration of the accuracy of a Samoan translation used during the election process; on all other issues, we affirm the NLRB order.

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Tanforan Park Shopping Center (“Tan-foran”) operates a shopping center in San Bruno, California. The center contains a restaurant complex consisting of various tenant restaurants around a common area.…