EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Other

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Employees who exercise choice in representative status have no right to insist upon bargaining free from economic disadvantages, and an employer’s use of economic pressures solely in support of a bargaining position cannot be held unlawful for that reason alone. An employer is entitled to withhold benefits that employees might have obtained had they remained unorganized so long as the employer engages in good faith bargaining.