By:  Kenneth R. Dolin

In continuing to apply strict scrutiny to workplace communications, the Board in a 2-1 panel decision recently held that an employer acted unlawfully by posting a memorandum shortly after a union election, urging employees to treat each other with “dignity and respect” and reiterating its workplace violence policy, even though the

By: Michael J. Rybicki, Esq.

Employers frequently express extreme frustration and bewilderment with respect to the Board and its decisions. We can only imagine how the owners of Plaza Auto Center, Inc. in Yuma, Arizona must feel following the Board’s Supplemental Decision in Plaza Auto Center, Inc., 360 NLRB No. 117, 199 LRRM