Hospitality Motor Inns began to bargain with the Hotel Employees Union after the NLRB certified the results of a representation election. A few days prior to this election, Hospitality had promoted the leading activist of the union among the employees to a supervisory position. Hospitality refused to entertain union proposals on dues checkoffs or union security, and the company insisted upon a broad management rights clause that would permit unilateral acts by the company regarding wages and other terms of employment. Hospitality cited "philosophical reasons" to justify its rejection of union proposals, including "no discrimination" and "no individual contracts" clauses in the agreement. After six months of bargaining sessions, the company's position did not change and no agreement was reached.
The union petitioned the Board, alleging that Hospitality Inns was bargaining in bad faith contrary to Section 8(a)(5) and (1). The company claimed that good faith bargaining does not require it to make "concessions" to the union. Decide. [NLRB v. Hospitality Motor Inns, 109 LRRM 2945 (6th Cir.)]