American Federation of Government Employees Local 1164 v. Federal Labor Relations Authority

Summary

The D.C. Circuit denied a union’s petition for review of an FLRA decision concerning whether the Social Security Administration was required to negotiate over a proposed hybrid workstation plan. The court held that it need not resolve the union’s argument regarding the applicable “appropriate arrangement” test because the FLRA had considered the proposal’s effect on efficient government operations as the union requested.

Holdings

1. The petition for review was denied because the FLRA conducted the inquiry the union claimed was required: it considered the proposal's effect on effective and efficient government operations and concluded that the proposal would lessen the Newport office's ability to serve the public efficiently.

Questions Presented

1. Whether the FLRA applied the correct test in determining that the union's proposed floor plan was not an appropriate arrangement negotiable under 5 U.S.C. § 7106(b)(3).
2. Whether the FLRA was required to apply the balancing approach from National Association of Government Employees, Local R14-87 and Kansas Army National Guard differently in light of American Federation of Government Employees, AFL-CIO, Local 1923 v. FLRA.

Disposition

writ_denied