Dresser-Rand Co. v. NLRB

After Dresser-Rand and the Union failed to negotiate the renewal of the union-members' employment contract, the union called off the strike and agreed to return to work without a contract. However, Dresser-Rand had locked out the union employees. After a week, Dresser-Rand reversed course and allowed the union members to return to work. The Board held that the lockout violated the National Labor Relations Act, 29 U.S.C. 151 et seq. The Board found that the lockout was motivated by antiunion animus based on actions that Dresser-Rand took after the lockout ended. The court held that that much of the later conduct did not violate the Act and the conduct that did violate the Act was not motivated by animus. Accordingly, the court concluded that these violations do not establish that the lockout was motivated by antiunion animus. Therefore, the court granted in part and denied in part Dresser-Rand's petition to deny enforcement of the Board's order. The court denied in part and granted in part the Board's cross-application for enforcement. View "Dresser-Rand Co. v. NLRB" on Justia Law