32 N.Y.2d 314 (1973)

A labor board’s determination of an appropriate bargaining unit is subject to narrow judicial review and will only be overturned if arbitrary or capricious, not merely if unsupported by substantial evidence.

Summary

This case concerns a dispute over the certification of Local 144 as the bargaining representative for the skilled maintenance employees of Long Island College Hospital. The hospital refused to bargain with the union, challenging the Labor Board’s determination of the bargaining unit and the conduct of the election. The New York Court of Appeals reversed the Appellate Division, holding that the Labor Board’s determination of the bargaining unit was within its broad discretion and that the election was fairly conducted. The Court emphasized the limited scope of judicial review of labor board decisions.

Facts

In 1963, Local 144 sought to represent the service and maintenance employees of Long Island College Hospital. The Labor Board directed two elections, one for service employees and one for skilled maintenance employees. The skilled maintenance employees voted to bargain as a separate unit and to be represented by Local 144. The hospital challenged the certification, refusing to bargain with the union.

Procedural History

The union initially pursued mediation and arbitration under Section 716 of the Labor Law. The hospital sought to restrain these proceedings, and the Court of Appeals initially ruled in favor of the hospital in Long Is. Coll. Hosp. v. Catherwood, 23 N.Y.2d 20 (1968), requiring the union to file an unfair labor practice charge. Subsequently, Local 144 filed a refusal to bargain charge with the Labor Board. The Board upheld its original certification order. The Appellate Division annulled the Board’s order and directed a new election. The Court of Appeals then reversed the Appellate Division’s decision.

Issue(s)

1. Whether the Labor Board’s determination that the hospital’s skilled maintenance employees constituted an appropriate bargaining unit was arbitrary or capricious.
2. Whether the conduct of the election, including the form of the ballot, the tabulation of the votes, and the union’s election campaign literature, was proper.

Holding

1. No, because the Labor Board has broad discretion in determining appropriate bargaining units, and its decision was not arbitrary or capricious.
2. Yes, because the Labor Board has the authority to determine the procedures for representation elections, and there was no evidence of substantial irregularities or abuse.

Court’s Reasoning

The Court of Appeals emphasized the broad discretion granted to the Labor Board in determining appropriate bargaining units, noting that such decisions are