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U.S. Court of Appeals for the Fourth Circuit

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12-1757

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Fourth Circuit upholds District Court decision; holds NLRB has no authority to issue posting regulation under the NLRA

June 14, 2013

The Fourth Circuit Court of Appeals upheld the decision of the district court and held that the NLRB does not have authority under the NLRA to promulgate the posting requirement. Below are some excerpts from the court's decision:

    NLRB appeals Poster Rule to Fourth Circuit

    November 05, 2011

    The NLRB appealed the decision of the U.S. District Court for the District of South Carolina to the Fourth Circuit Court of Appeals. The District Court ruled that the NLRB violated the Administrative Procedure Act (APA) in promulgating the rule. The court noted that nothing in the National Labor Relations Act (NLRA) “even mentions the issue of notice posting” (emphasis added) - much less compels or even permits the NLRB to issue such a rule. The NLRB has appealed to the Fourth Circuit.

    NLRB’s opening brief filed with the Fourth Circuit on 9/28/12. NCLC filed its response brief on 11/28/12. The NLRB’s reply brief filed on 12/20/12. Decided 6/14/13.

    Complaint filed 9/19/2011 before U.S. District Court for the District of South Carolina. On 10/5/11, the NLRB postponed the effective date of the final rule until 1/31/12. Chamber's Motion for Summary Judgment filed 11/9/11. National Labor Relations Board's Motion for Summary Judgment filed 11/9/11. NCLC's Memorandum in Opposition filed 12/7/11. NLRB’s Memorandum in Opposition filed 12/7/11. On 12/23/11, the NLRB further postponed the effective date of the final rule until 4/30/12. District court decision 4/13/12. On 4/17/12, the DC Circuit enjoined enforcement of the rule pending an appeal of a related lawsuit.

    Decided 6/14/2013. Petition for Rehearing filed 7/29/2013. Petition Denied 8/12/2013.

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