Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 336 (2002). In Cape Cod Regional Technical High School District Committee, supra, the DLR held that there was no reasonable ground for a teachers assertion that she believed that a private meeting with the principal might lead to discipline when the teacher did not ask the purpose of the meeting and no other factors suggested the meeting would be disciplinary.
Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 336 (2002). In Cape Cod Regional Technical High School District Committee, supra, the DLR held that there was no reasonable ground for a teachers assertion that she believed that a private meeting with the principal might lead to discipline when the teacher did not ask the purpose of the meeting and no other factors suggested the meeting would be disciplinary.
Town of Carver, 35 MLC disparate treatment, at 48; Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 335 (2005); Bristol County, 26 MLC 105, 109 (2000); Town of Andover, 14 MLC at 1582, aff'd 17 MLC (1989). at 1482: Groveland 1464, 1478 Timing alone is insufficient to establish the element of unlawful motivation. City of Malden, 5 MLC 1752, 1764 (1979). 17 School Committee, 16 MLC H.O.
Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 335 (1992); Bristol County, 26 MLC Here, Longs disagreement with his supervisor took 105, 109 (2000). place approximately eight years ago, which is too distant in time to establish a connection with MassDOTs March 2011 actions.
.; Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 335, MUP-2541 (May 15, 2002). Timing alone is insufficient to establish unlawful employer motivation. City of Newton, 32 MLC 37, 48, MUP-2849 (June 29, 2005); City of Malden, 5 MLC 1752, 1764, MUP-3017 (March 20, 1979). The Union presented no direct or indirect evidence to establish the Employer's unlawful motivation.
Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 336, MUP-2541 15, 2002) (citing Groton-Dunstable Regional School Committee, (May 15 MLC at 1556-57). Expressions of employer anger, criticism, and ridicule directed at employees' protected activities are sufficient to constitute interference, restraint, and coercion of employees.
Town ofCarver, 35 MLC at 48; Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 335, MUP-2541 (May 15, 2002); Bristol County, 26 MLC 105, 109, MUP-2100 (Jan. 28, 2000); Town of Andover, 14 MLC 1571, 1582, MUP-6443 (H.O. March 3, 1988), affd 17 MLC 1475, 1482, MUP6443 (Feb. 6, 1991). The Charging Parties produced no evidence showing that there was a difficult or contentious relationship between NAGE and the Commonwealth.
Town ofCarver, 35 MLC at 48; Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 335, MUP-2541 (May 15, 2002); Bristol County, 26 MLC 105, 109, MUP-2100 (Jan. 28, 2000); Town of Andover, 14 MLC 1571, 1582, MUP-6443 (H.O. March 3, 1988), affd 17 MLC 1475, 1482, MUP6443 (Feb. 6, 1991). The Charging Parties produced no evidence showing that there was a difficult or contentious relationship between NAGE and the Commonwealth.
Town of Carver, 35 MLC at 48 (citing Melrose School Committee, 33 MLC 61, 69, MUP-02-3549 (Sept. 27, 2006)); Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC at 335; Bristol County, 26 MLC 105, 109, MUP-2100 (Jan. 28, 2000); Town of Andover, 14 MLC 1582, MUP-6443 (H.O. March 3, 1988), affd 17 MLC 1475, 1482, MUP-6443 (Feb. 6, 1991). The Unions retaliation claim fails at the first prong.
Cape CodRegionalTechnicalHighSchool District Committee, 28 MLC 332, 336, MUP-2541 (May 15, 2002) (citing Groton-Dunstable Regional School Committee, 15 MLC 1551, 1556-57, MUP6748 (March 20, 1989)). Expressions of anger, criticism, and ridicule directed by an employer against employees protected activities may be sufficient to constitute a violation of the Law. Id.