Drug Plastics & Glass Company, Inc. v. National Labor Relations Board

On rehearing, the court reaffirms that the appropriate time for determining the requisite relatedness of the complaint and charge allegations is at the time the complaint is filed. In so doing, the court also emphasizes the perils for the Board of relying on boilerplate language, albeit this time with regard to the complaint in addition to the charge. Cf. Lotus Suites, Inc. v. NLRB, 32 F.3d 588, 592 (D.C.Cir.1994); G.W. Galloway Co. v. NLRB, 856 F.2d 275, 278 (D.C.Cir.1988). Absent allegations on the face of the complaint that make apparent their factual relationship to the allegations in a…