UNFAIR PRACTICE ISSUES; PROTECTED ACTIVITIES – Individual/Concerted/Activities/Self-Representation

Single Topic for Decision 2420E

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Charging party’s attendance at the hearing concerning another employee was not protected, because there was insufficient evidence to establish that the purpose for his attendance was to investigate possible contract violations or other policy violations. That there may have been others at the hearing is irrelevant to the finding that no evidence was presented showing how or why the other employee’s employment dispute had anything to do with charging party’s disputes with the employer. The Board declined to affirm the ALJ’s conclusion – consistent with Board precedent – that charging party’s request for personal necessity leave under the CBA was not protected because it was not a “logical continuation of group activity,” saving for another day full consideration of whether the Board’s precedent should be overturned.