Commonwealth of Massachusetts, 40 MLC at 299 (citing Town of Winchester, 19 MLC 1591, 1596-97, MUP-7514 (Dec. 22, 1992)). The Commonwealth employment Relations Board (CERB) does not analyze the motivation behind the conduct, Town of Chelmsford, 8 MLC 1913, 1916, MUP-4620 (March 12, 1982), aff'd sub nom. Town of Chelmsford v. Labor Relations Commission, 15 Mass. App. Ct. 1107 (1983), or whether the coercion succeeded or failed.

Town of Winchester, 19 MLC 1591, 1597, n.9, MUP-7514 (December 22, 1992) (examining selectmens statements as a whole when determining whether a Section 10(a)(1) violation occurred).

Town of Winchester, 19 MLC 1591, 1597, n.9, MUP-7514 (December 22, 1992) (examining selectmens statements as a whole when determining whether a Section 10(a)(1) violation occurred). review, upon However, Kings comments contain expressions of anger and ridicule coupled with a threatening remark directed at Ogaldezs Committee, posting on 35 MLC a website complaints 199, 217, about constitutes unlawful criticism). to the Union MUP-04-4008 access to about

Assessors of Boston, 383 Mass. 456, 420 N.E.2d 298 (1981) 9 Oil, Chemical and Atomic Workers and Ceremuga, 270 NLRB 311 (1984) 17 Salem School Committee, 35 MLC 199 (2009) 12 Steelworkers Local 1397, 240 NLRB 848 (1979) 16 Teamsters, Local 391 and Barry Sawyers, NLRB No. 187 (2012) 17 Town of Bolton, 32 MLC 20 (2005) 12 Town of Winchester, 19 MLC 1591 (1992) 12 Vaca v. Sipes, 386 U.S. 171, 87 S. Ct. 903, 17 L.

Town of Winchester and Service Employees International Union, Local 888, 2015 WL 4061670, at *4 (stating the Union bears the burden of affirmatively proving the impact of an employer's change and that the DLR will not infer such an impact) (citing Town of Seekonk, 14 MLC 1725, 1730-31, MUP-6131 (May 10, 1988)).

Town of Winchester, 19 MLC 1591, 1596 (1992). Under this test, the Division has found expressions of employer anger, criticism and ridicule directed at employees protected activities sufficient to constitute interference, restraint and coercion of employees. Groton-Dunstable Regional School Committee, 15 MLC at 1556-1557.

Town of Winchester, 19 MLC 1591, 1596 (1995). Rather, the focus of the inquiry is the effect of the employer's conduct on a reasonable employee. City of Boston, 20 MLC 1154, 1161 (1994).

Bristol County Sheriffs Department, 31 MLC at 15 (citing Town of Winchester, 19 MLC 1591, 1596, MUP-7514 (Dec. 22, 1992)). subjective impact that the determinative of a violation. Town of Winchester, employer's conduct had on a specific employee The is not Bristol County Sheriffs Department, 31 MLC at 15 (citing 19 MLC at 1596)).

Vernon St Winchester, MA 01890 781 2022 Last day to register to vote for the Primary is August 27, 2022 aste information, including archived information, regarding the following property: 440 and 450 Arsenal Stre requested information as soon as possible. I understand a fee may be associated with delivery of the reques on as soon as possible. I understand a fee may be associated with delivery of the requested materials.

Town of Winchester, 19 MLC 1591, 1596, MUP-7514 (December 22, 1992). The Commonwealth Employment Relations Board (CERB) does not analyze the motivation behind the conduct, Town of Chelmsford, 8 MLC 1913, 1916, MUP-4620 (March 12, 1982), affd sub nom. Town of Chelmsford v. Labor Relations Commission, 15 Mass. App. Ct. 1107 (1983), or whether Complaint and Partial Dismissal (cont'd) MUP-17-6000 the coercion succeeded or failed.

Compare Commonwealth of Massachusetts, 34 MLC 115, 119, SUP-03-5023 (April 11, 2008) (rejecting Commonwealths argument that change in inmates exercise schedule did not require bargaining, where change required correction officers to assume additional responsibilities without changing their schedule) to Town of Winchester, 42 MLC at 332-333 (affirming H.O. dismissal of complaint where Union failed to demonstrate any impact on workload by the hiring

Andover Education Assoc., 40 MLC 1 (2013) (finding an e-mail to approximately sixty bargaining unit members about contract negotiations was protected) citing Town of Winchester, 19 MLC 1591, 1597 (1992), Burgess was interrogated about her e-mail urging employees to wear purple in support of Union negotiations and that such support be dedicated to a particular member who was recently unfairly disciplined.

Town of Winchester, 42 MLC 332, MUP- 18 13-3289, (June 23, 2016) (citing Town of Seekonk, 14 MLC 1725, 1730-31, MUP-6131 19 (May 10, 1988)). It is undisputed that the Town failed to provide the Union with an 20 opportunity to bargain over the workload impacts of its decision to require members of 21 the bargaining unit to respond to all calls for service at the College campus requiring 22 sworn personnel and/or an investigation.