International Ladies' Garment Workers' Union v. Quality Manufacturing Co.

Supreme Court of the United States · 1974 · Labor Law

Labor LawUnion RepresentationInvestigatory InterviewsUnfair Labor PracticesNLRASection 7Section 8(a)(1)Section 8(a)(3)

Facts

After a contentious meeting about wages, the employer directed employee Catherine King to meet with the company president alone after an incident on the shop floor. King requested union representation and refused to submit to an interview without her union representative because she reasonably believed the interview might lead to discipline. Shop chairlady Delila Mulford and assistant chairlady Martha Cochran attempted to represent King, were suspended for doing so, and Mulford was later discharged; King was discharged after again refusing to meet alone. Cochran was also discharged after attempting to file grievances on behalf of King, Mulford, and herself.

Issue

Whether an employer violates § 8(a)(1) of the NLRA by denying an employee's request for union representation at an investigatory interview that the employee reasonably believes may result in disciplinary action, and by disciplining employees for asserting or assisting in that right.

Rule

When an employee reasonably believes that an investigatory interview may result in disciplinary action, the employee's request for union representation is protected concerted activity for mutual aid or protection under § 7 of the NLRA. An employer's denial of that request, and discipline imposed for asserting or assisting in that protected activity, constitutes an unfair labor practice under § 8(a)(1).

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

At a unionized appliance plant in Toledo, employee Rosa Medina is told to report to the operations manager after a supervisor claims Rosa ignored a safety instruction. Rosa asks that union steward Evan Pike attend because she believes the meeting could lead to discipline. The manager refuses any representative and terminates Rosa when she declines to go in alone.

Which is the strongest assessment under the governing rule?

Explanation. The majority applied the rule that when an employee reasonably believes an investigatory interview may result in disciplinary action, the employee's request for union representation is protected concerted activity under § 7. Denying that request and discharging the employee for insisting on it interferes with that protected right and violates § 8(a)(1). (Derived from International Ladies' Garment Workers' Union v. Quality Manufacturing Co. (n.d.).)