Honeyville Grain, Inc. v. National Labor Relations Board

In seeking to set aside union certification election, employer bore preliminary burden of showing that union representative’s challenged religious remarks were inflammatory or represented core of union’s campaign; union agents’ remarks, describing employers as Mormons and asserting that company profits donated to Mormon church should instead be passed to employees, were wholly inappropriate but were neither inflammatory nor basis of campaign to unionize; thus, election could not be set aside.

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