Electromation Inc
Electromation Inc 309 NLRB No 163 (1992) is a US labor law case related to employer domination of labor organizations. Facts Teamsters Local 1049 claimed recognition for collective bargaining at Electromation Inc, which was not unionized. Teamsters claimed that Electromation Inc's practice of using "action committees" to hear worker opinions was an unlawful company union under National Labor Relations Act of 1935 §8(a)(2). The employer told the action committees that it could not continue to work with them, but even though they were discontinued, the Board heard the union's violation charge. Electromation had five 'action committees' to deal with complaints on wages, bonuses, incentive pay, attendance programs and leave policies. There were five employees and a management representative for each one, and the Employees Benefits Manager was also on each committee, who said 'management expected that employee members on the Committees would kind of talk back and forth with the other employees in the plant, get their ideas, and that... anyone [who] wanted to know what was going on, they could go to these people on the Action Committees.' Judgment The National Labor Relations Board held, the committees were a §2(5) labor organization and management had dominated it, so there