Is it unfair labor practice for an individual employer to voluntarily recognize a union which does not enjoy majority support?

MultiRegion, United States of America

The following excerpt is from N.L.R.B. v. Silver Spur Casino, 623 F.2d 571 (9th Cir. 1980):

6 In the formation of multi-employer units, it is an unfair labor practice for an individual employer to voluntarily recognize a union which does not enjoy majority support among that employer's employees. Thus when employers join a multi-employer unit and recognize the union, they are viewed as implicitly declaring that the majority of their employees favor the union. Subsequent withdrawal from the multi-employer unit simply entails a reversion to the original unit, a unit previously determined from the employer's own conduct to favor the union's representation. NLRB v. Tahoe Nugget at 303.

7 Respondents correctly quoted a passage from Celanese which states that:

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