Headnote for 2664M, 1205.10 Other Affirmative Relief - California Public Employment Relations Board

REMEDIES FOR UNFAIR PRACTICES; MISCELLANEOUS REMEDIAL PROVISIONS – Other Affirmative Relief

Single Topic for Decision 2664M

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1205.00000 – REMEDIES FOR UNFAIR PRACTICES; MISCELLANEOUS REMEDIAL PROVISIONS
1205.10000 – Other Affirmative Relief

Where employer withdrew a contact proposal as part of an overall course of bad faith conduct, the Board clarified that the remedial order requiring the employer to bargain in good faith required the employer to reinstate the withdrawn offer. (Mead Corp. v. NLRB (11th Cir. 1983) 697 F.2d 1013, 1022-1023, enforcing The Mead Corp. (1981) 256 NLRB 686.) Such a Mead Corp. order was necessary to restore the situation as nearly as possible to that which would have existed but for the employer’s bad faith conduct and was integral to requiring the employer to cease and desist from its unlawful conduct. Employer therefore directed to put back on the table the proposal it withdrew in bad faith, upon the Union’s request.