In late 2017, Congress reduced the corporate tax rate. In January 2018, an Employer informed its non-union employees that “the new corporate tax rate will produce a financial benefit . . . and the Company wants to extend that benefit to our employees via a one-time bonus and an increase in the 401K match.”  The Employer’s announcement stated…

Steward Kaanta, a member of UAW Local 828 but not a member of the union’s bargaining committee, requested the Company provide him information about financial relationships between it and members of the union “for the purpose of future bargaining.” He then requested various employee payroll records. After these requests, the Company consulted with the Union…