LABOR - The D.C. Circuit held that the National Labor Relations Board properly vacated a union certification and ordered a new election. Because the company and the union invoked the board's election procedures to certify the union, the board may use this same procedure to undo the improper election. New York Rehabilitation Care Managementv. NLRB
EMPLOYMENT - An Environmental Protection Agency employee claimed that his supervisor racially discriminated against him by interfering with how he supervised his own employees. The D.C. Circuit found that the employee failed to show how his supervisor's interferences impaired his own job performance. Patterson v. Johnson
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