Prill\Meyers Industries In order for employee actions to be protected under Section 7, they must be concerted for mutual aid and protection Prill\Meyers Industries (1987): concertedness must be explicit, must act on authority of at least one other ee ee must explicitly satisfy both criteria; concertedness not presumed Alleluia Cushion (1975) concertedness presumed if at least one other other ee benefits
Prill\Meyers Industries (cont.) City Disposal (S.C. 1984) concertedness presumed under CBK
Prill\Meyers Industries Court in Meyers I remanded because Board had held that its Meyers doctrine on concerted activity mandated by NLRA Court not mandated - remanded for reasoning (Meyers 1) either Meyers or Alleluia interpretation is reasonable (Meyers II)