## Facts

- A labor organization representing major-league umpires sought certification as the exclusive bargaining representative for umpires working under a league-administered employment structure.
- The American League, acting through a coordinated, multi-club arrangement for employing and administering umpires, opposed the proposed unit and/or disputed whether the league entity was the proper bargaining counterpart.
- The case arose on a representation petition requiring the National Labor Relations Board to determine (1) whether the league’s coordinated arrangement qualified as an employer (or employers’ association) for National Labor Relations Act purposes and (2) whether the petitioned-for grouping of umpires was an appropriate bargaining unit under NLRA § 9(b).
- The umpires’ work was characterized by uniform job functions and league-wide administration of core employment matters (e.g., assignment and discipline), rather than team-by-team control.

## Issues

1. Whether the American League’s coordinated, multi-club arrangement could be treated as an employer (or employers’ association) that may bargain collectively with umpires under the NLRA.
2. Whether a league-wide group of major-league umpires constituted an “appropriate unit” for collective bargaining under NLRA § 9(b).

## Decision

- The NLRB determined that the American League’s organized, multi-club arrangement functioned as a proper employing entity (or employers’ association) for purposes of collective bargaining with the umpires’ representative.
- The NLRB found the petitioned-for league-wide unit of umpires to be an appropriate bargaining unit under NLRA § 9(b).
- The decision permitted the representation process to proceed (including an election and, if selected, bargaining) on a league-wide basis with the league-level employer entity.
- One Board member dissented.

## Legal Principles

- The NLRB has discretion under NLRA § 9(b) to designate an appropriate bargaining unit; the selected unit need not be the only or most appropriate unit if it is reasonable under the Act.
- A league-level or multi-employer structure may be recognized as the bargaining counterpart when control over key terms and conditions of employment is sufficiently centralized to permit meaningful collective bargaining.
- A league-wide unit is appropriate where employees share a strong community of interest, including substantially similar job functions and centrally administered terms and conditions of employment.
- In evaluating unit appropriateness, the Board may consider whether a broader unit reduces fragmentation that would impair labor-relations stability in an integrated enterprise.

## Conclusion

The NLRB treated the American League’s centralized, multi-club umpire employment arrangement as a proper employer (or employers’ association) and approved a league-wide bargaining unit of major-league umpires, allowing representation and bargaining to proceed on that basis.


The American League of Pro. Baseball Clubs & Ass'n of Nat'l Baseball League Umpires, 180 N.L.R.B. 190 (1969)