REPRESENTATION ISSUES; OBJECTION TO ELECTIONS – Union Conduct

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Like the National Labor Relations Board (NLRB), PERB protects against campaign misconduct such as threats, promises or the like, which interfere with employee free choice, as well as against statements made in a fraudulent manner preventing an employee from evaluating the truth of the statement. (Midland National Life Insurance Co. (1982) 263 NLRB 127; see also Triple E Produce Corp. v. Agricultural Labor Relations Bd. (1983) 35 Cal.3d 42, 50.)