New York and Presbyterian Hosp. v. N.L.R.B

1 Citing case

  1. Price v. Unite Here Local 25

    883 F. Supp. 2d 146 (D.D.C. 2012)   Cited 6 times
    Explaining that parties may enter into an enforceable side agreement that supplements original collective bargaining agreement

    Side letters mutually agreed to by the parties in a collective bargaining relationship may supplement the original collective bargaining agreement. See N.Y. & Presbyterian Hosp. v. NLRB, 649 F.3d 723, 726 (D.C.Cir.2011) (“the collective bargaining agreement ... includes a ‘side letter’ ”); see also Moreau v. James River–Otis, Inc., 652 F.Supp. 1030, 1031 (D.Me.1987) (“The proposed side agreement constituted an exception to the general provision in the collective bargaining agreement....”); Evansville–Vanderburgh Sch. Corp. v. Evansville Teachers Ass'n, 494 N.E.2d 321, 325–26 (Ind.Ct.App.1986) (side letter that declared “this letter will serve to supplement the collective bargaining agreement” was part of the collective bargaining agreement). Hence, even if the probationary period established in the Letter of Agreement conflicts with provisions of the master CBA, the terms agreed to in the side letter control this case.