Court: Brookline must bargain with union with less than 10 members

LYNN, J. The respondent, the Town of Brookline (the Town), appeals the decision of the New Hampshire Public Employee Labor Relations Board (PELRB), based upon stipulated facts and exhibits, which found that the Town engaged in an unfair labor practice by refusing to bargain with the petitioner, AFSCME, Council 93 (Union). On appeal, the Town argues that the PELRB erred by ruling that the Town had a duty to bargain with the Union even though the bargaining unit in question, originally certified in 2001, currently contains fewer than ten employees. We affirm.
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