Town of Lenox, 29 MLC 51 (2002) (citing Town of Dennis, 26 MLC 203 (2000)). It is well-established that the six- month limitations period begins to run when the party adversely affected receives actual or constructive notice of the conduct alleged to be an unfair labor practice. Id. (citing Wakefield School Committee, 27 MLC 9, 10 (2000)).

Town of Dennis, 29 MLC 79, 83 (2002); Town of Clinton, 12 MLC 1365 (1985); Boston City Hospital, 11 MLC 1361, 1361, 1365 (1985). Assuming that the Union can demonstrate that PO Gomez-Brown engaged in protected activity under 10(a)(4), which it cannot, the Union still cannot meet its burden. The Trial Court took no adverse action against PO Gomez-Brown. An adverse action must materially disadvantage the affected employee in some way.

Town of Dennis, 29 MLC 79, 83 (2002); Town of Clinton, 12 MLC 1361, 1365 (1985); Boston City Hospital, 11 MLC 1361, 1365 (1985). Local 6s case fails every prong required to make a prima facia case. It is unclear even after filing their complaint with DLR what protected activity Local 6 alleges the maintenance workers engaged in.

Ct. 926 (1992); Town of Lenox, 29 MLC 51, 52, MUP-01-3214 and MUP-01-3215 (Sept. 5, 2002) (citing Town of Dennis, 26 MLC 203, 204-05, MUP-1868 (April 21, 2000)). Thus, in unilateral change cases, the timeliness of a charge turns on when the union knew or should have known that the employer had implemented a change affecting a mandatory subject of bargaining without first satisfying its Section 6 bargaining obligation.

eliminate the SSI 18 decision insulated from the statutory obligation to bargain. 19 MLC 20 decision did not change the level of SSI services provided to the citizens because there 21 was no reduction in the number of superior officers working for the City or a change in 22 any particular assignment. 23 fact that the decision resulted in one less bargaining unit position. 1027, 1030, n. 4, MUP-5247 Supervisor title was not a level of services Citing Town

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Town of Dennis, 3 MLC 1014, MUP-2129 (June 30, 1976) (citing Blasingame Well Service, 174 NLRB 1126 (1969)). 7 5 Complaint and Partial Dismissal (cont.) MUP-21-8876 candidates whom the Union supported.8 Nestors role in all three activities was visible to the Employer. Nonetheless, the Union is unable to meet the third element of its case, as the Employer did not take any adverse action against Nestor.

See Town of Dennis, 28 MLC 297, 302 (2002) (An employer relying on exigent circumstances in negotiations must establish that those circumstances required the imposition of a deadline on negotiations, the deadline was reasonable and necessary, and the employee organization was on notice that the change would be implemented on a certain date).

Town _of Lenox, 29 MLC 51, MUP-01-3214, MUP-01-3215 (September 5, 20020(citing Town of Dennis, 26 MLC 203, 205, MUP-1868 (April 21,2000); Felton v. Labor Relations Committee, 33 Mass. App. Ct. 926, 928 (1992). The six-month period of limitations for filing charges begins to run when the adversely affected party receives actual or constructive notice of the conduct alleged to be an unfair labor practice.

Ct. 926 (1992); Town of Dennis, 26 MLC 203 (2000). The six-month period of limitations begins to run when the adversely affected party receives actual or constructive notice of the alleged violation. Town of Lenox, 29 MLC 51, 52 (2002). * The Association provided a copy of this grievance and associated demand for arbitration at the in-person investigation.