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NLRB Dana Corp. Decision Marks Change In Doctrine

Law360 (October 12, 2007, 12:00 AM EDT) -- In Dana Corp., 351 NLRB No. 28 (Sept. 29), the National Labor Relations Board (the “Board”) held that an employer’s voluntary recognition of a labor organization does not bar a decertification petition or a rival union’s petition for an election that is filed within 45 days of notice to employees of voluntary recognition. In addition, the Board determined that a collective bargaining agreement executed on or after the date of the employer’s voluntary recognition will not bar such petitions, unless employees receive notice of the recognition...
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