Suffolk County Sheriff's Department, 27 MLC 155, 160 (2001); Quincy School Committee, 27 MLC 83, 92 (2000). The charging party bears the burden of proving that, but for the protected activity, the employer would not have taken the adverse action. Athol-Royalston Regional School Committee, 28 MLC 204, 214 (2002); Town of Athol, 25 MLC at 211.

Suffolk County Sheriffs Department, 27 MLC 155, 159, MUP-1498 (June 4, 2001). Finally, if the employer produces one or more lawful reasons for taking the adverse action against the employee, the charging party must establish that but for the protected activity, the employer would not have taken the adverse action. Id.

Suffolk County Sheriff's Department, 28 MLC 253, 259 (2002) (citing SEIU, Local 509, 431 Mass. at 710)). Second, direct dealing undermines the employees' belief that the union actually possesses the power of exclusive representation to which the statute entitles it. Id. These are exactly the reasons SPAM put forward and these are exactly the reasons that were rejected.

Suffolk County Sheriffs Department, 27 MLC 155, 159, MUP-1498 (June 4, 2001).

Suffolk County Sheriffs Department, 28 MLC 253, 259, MUP-2840 (January 30, 2002) (citing Service Employees International Union, AFL-CIO, Local 509 v. Labor Relations Commission, 431 Mass. 710, 715 (2000)). Second, direct dealing undermines the employees belief that the Union actually possesses the power of exclusive representation to which the statute entitles it. Id. at 259.

See Suffolk County Sheriffs Department, 29 MLC 21, 27-28, MUP-01-2911 (July 18, 2002). Thus, I find the Union had sufficiently clear notice that the Towns conduct was causing it an injury in the months and weeks prior to March 29, 2022.

Suffolk County Sheriffs Department, 30 MLC 1, 6 (2003). When the language of a provision at issue is ambiguous, the Board will look to the bargaining history to determine whether there was a clear agreement between the parties. | Massachusetts State Lottery Commission, 22 MLC at 1552, (citing Commonwealth of Massachusetts, 18 MLC 1161, 1163 (1991)).

See Suffolk County Sheriff's Department, 27 MLC at 159. 1. Count I concerns the Respondents retaliatory failure to pay Dr. Bryans hotel expenses incurred during an approved conference presentation during October 2013. 3 2. On September 18, 2013, Dr. Bryan emailed Mr. DeMelo of the Respondents travel office seeking approval for a car rental in conjunction with his conference travel.

Suffolk County Sheriff's Department, 27 MLC 155, 159, MUP- 9 1498 (June 4, 2001 ). Finally, if the employer produces one or more lawful 10 reasons for taking the adverse action against the employee, the charging 11 party must establish that "but for" the protected activity, the employer would not 12 have taken the adverse action. !

Suffolk County Sheriffs Department, 27 MLC 155, 159, MUP-1498 (June 4, 2001).

AtholRoyalston School Committee, 28 MLC at 219 (eliminating department chairs discretion over certain funds and not consulting him regarding field trips constituted adverse action where CERB inferred that school principal engaged in the conduct to punish employee for complaining and filing grievances); Suffolk County Sheriffs Department, 27 MLC 155, 159, MUP-1498 (June 4, 2001) (inferring that employers decision not to assign employee to assignment

Suffolk County Sheriff's Department, 27 MLC 155, MUP-1498 (June 4, 2001).