For example, in the Town of Winchester, 19 M.L.C. 1591, 1597 (1992), a selectman commented on and read a letter by a Town employee to newspapers in neighboring towns sarcastically criticizing the Towns position in fire negotiations. In Town of Winchester, similar to this case, the conduct of the employee (Practice Areas/LABOR/23624/00039/A2430629,D0C) 6 was protected.

Town of Winchester, 19 MLC 1591, 1596, MUP-7514 (December 22, 1992). The Commonwealth Employment Relations Board does not analyze either the motivation behind the conduct or whether the coercion succeeded or | failed. Town of Bolton, 32 MLC 13, MUP-01-3254 (June 27, 2005). Instead, the Board considers the objective impact that the employers conduct would have on a reasonable employee under the circumstances.

Quincy School Committee, 27 MLC 83, 91, MUP-198 6 (December 29, 2000); Town of Athol, 25 MLC 209. 212, MUP-1448 (June 11, 1999); Town of Winchester, 19 MLC 1591, 1595, MUP-7514 (December 22, 1992); Groton9 Complaint and Partial Dismissal (cont'd) MUP-17-6235 Dunstable Regional School Committee, 15 MLC 1551, 1555, MUP-6748 (March 20, 1989).

Town of Winchester, 24 MLC 44 (1997). The Commission held that the Town did not commit a unilateral change with regards to its grooming policy. In that case, the Town did not publish a policy, did not post the policy, did not update the policy, nor did it give new hires a copy of the policy. The Policy was implemented by one Chief based upon his practice.

infrastructure improvements necessary to serve the needs of emergency 713 responders in Hampshire, Hampden and Franklin counties; provided further, that not less than 714 $300,000 shall be expended for the modernization of communications systems and equipment 715 for the town of Stoneham police department; provided further, that not less than $300,000 shall 716 be expended for the modernization and upgrade of emergency communications systems in the 717 town

infrastructure improvements necessary to serve the needs of emergency 713 responders in Hampshire, Hampden and Franklin counties; provided further, that not less than 714 $300,000 shall be expended for the modernization of communications systems and equipment 715 for the town of Stoneham police department; provided further, that not less than $300,000 shall 716 be expended for the modernization and upgrade of emergency communications systems in the 717 town

Quincy School Committee, 27 MLC 83, 91, MUP-1986 (December 8, 2000); Town of Athol, 25 MLC 208, 212, MUP-1448 (June 11, 1999); Town of Winchester, 19 MLC 1591, 1595, MUP-7514 (December 12, 1992); Groton-Dunstable Regional School Committee, 15 MLC 1551, 1555, MUP-6748 (March 20, 1989). The focus of a Section 14 10(a)(1) analysis is the effect of the employer's conduct on reasonable employees' exercise of their Section 2 rights.

Town of Winchester, 19 MLC 1591, 1596, MUP-7514 (December 13 22, 1992). Proof of illegal employer motivation is not required to establish a Section 14 10(a)(1) violation. Town of Chelmsford, 8 MLC 1913, 1916, MUP-4620 (March 12, 1982) 15 affd sub nom. Town of Chelmsford v. Labor Relations Commission, 15 Mass App. Ct. 16 1107 (1983). It also does not matter whether the coercion succeeded or failed.

Town of Bolton, 32 MLC 13, 22 MUP-01-3254 (June 27, 2005) (citing Town of Winchester, 19 MLC 1591, 1596, MUP- 23 7514 (December 22, 1992)). In this respect, an objective employee who exercised their 18 H.O.

Quincy School Committee, 27 MLC 83, 91, MUP-1986 (December 8, 2000); Town of Athol, 25 MLC 208, 212, MUP-1448 (June 11, 1999); Town of Winchester, 19 MLC 1591, 1595, MUP-7514 (December 12, 1992); Groton-Dunstable Regional School Committee, 15 MLC 1551, 1555, MUP-6748 (March 20, 1989). The focus of a Section 14 10(a)(1) analysis is the effect of the employer's conduct on reasonable employees' exercise of their Section 2 rights.

Town of Winchester, 19 MLC 1591, 1596, MUP-7514 (December 13 22, 1992). Proof of illegal employer motivation is not required to establish a Section 14 10(a)(1) violation. Town of Chelmsford, 8 MLC 1913, 1916, MUP-4620 (March 12, 1982) 15 affd sub nom. Town of Chelmsford v. Labor Relations Commission, 15 Mass App. Ct. 16 1107 (1983). It also does not matter whether the coercion succeeded or failed.

Town of Bolton, 32 MLC 13, 22 MUP-01-3254 (June 27, 2005) (citing Town of Winchester, 19 MLC 1591, 1596, MUP- 23 7514 (December 22, 1992)). In this respect, an objective employee who exercised their 18 H.O.

Town of Winchester, 19 MLC at 1596. The Board does not analyze the motivation behind the conduct, Town of Chelmsford, 8 MLC 1916 (1982), affd sub nom., Town of Chelmsford v. Labor Relations Commission, 1913, 15 Mass. App. Ct. 1107 (1983), or whether the coercion succeeded or failed. Groton-Dunstable Regional School Committee, 15 MLC at 1551.

Town of Winchester, 19 MLC 1591 (1992). Here, while a technical error, VP Sissons email does not rise to the level of what would be considered a threat by a reasonable objective employee and is not a violation of the Law. Furthermore, VP Sissson has apologized for his email several times to the grievant and the Union in-person at subsequent Step 1 grievance hearings held not long after the email was sent.

The focus of a Section Quincy School Committee, 27 MLC 83, 91 (2000). 10(a)(1) analysis is the effect of the employer's conduct on reasonable employees exercise of their Section 2 rights. 1591, 1596 (1992). the Law, Town of Winchester, 19 MLC To determine whether an employer has violated Section 10(a)(1) of the Board applies an objective test that focuses on the impact that the employers conduct would have on a reasonable employee rather than the