1994), the Court of Appeal analysed the employer`s historical practice of determining the frequency and level of wage increases and found that the granting of a wage increase was not left to the discretion of the employer and could not be decided without negotiation with the union (see also The Daily News of Los Angeles v. NLRB, 979 F.2d 1571 [D.C Cir. 1992] Timing, But discreetly with regard to the amount are considered mandatory subjects of negotiation]). Once the NLRB certifies a union as the exclusive negotiator, the union enjoys an irrefutable presumption of majority support for one year (River Dyeing & Finishing Corp. v. NLRB, 482 U.p. 27, 107 pp. Ct. 2225, 96 L.

Ed. 2d 2d 22 [1987]). During that year, the employer may not refuse to negotiate with the union on the grounds that the union does not represent the majority of the workers. .

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