Doyle, Jr. v. Covenant House NY
John D. Doyle, Jr., Regional Director of Region 2 of the National Labor Relations Board for and on behalf of the National Labor Relations Board v. Covenant House NY
- Ronnie Abrams
- 1:25-cv-03642
- U.S. District Court · Southern District of New York
- 3
In Doyle v. Covenant House NY, Judge Abrams allowed caucus time in bargaining sessions but kept cease-and-desist and posting requirements.
The order affects Covenant House NY and the National Labor Relations Board, particularly the terms governing Covenant House NY’s bargaining obligations under the previously granted injunction.
What happened
In Doyle v. Covenant House NY, the court resolved disputes about the written terms of an injunction it had already granted to the National Labor Relations Board.
Covenant House NY objected to excluding caucus time from bargaining-session limits, requiring it to stop certain unfair bargaining practices, and requiring it to post physical copies of the court’s order. The court agreed that caucus time should count toward the session length, but rejected the other objections.
Judge Ronnie Abrams ordered the National Labor Relations Board to submit a revised proposed order by September 3, 2025. The written order will include cease-and-desist and posting provisions, and the Board may notify the court if Covenant House NY appears to misuse caucuses to avoid bargaining.
The detailed version
- Doyle, Jr. v. Covenant House NY · No. 1:25-cv-03642
- Ronnie Abrams
- Aug. 27, 2025
Background
On August 13, 2025, the Court granted the National Labor Relations Board’s request for an injunction under Section 10(j) of the National Labor Relations Act. The Court then asked the parties to address disputes about the terms of the written injunction order.
Covenant House NY objected to three proposed provisions: excluding “caucus time” from the required length of each bargaining session; requiring Covenant House NY to “cease and desist” from certain unfair bargaining practices; and requiring it to post physical copies of the Court’s order.
Court’s Analysis
The Court agreed that caucus time should not be excluded from the length of bargaining sessions. It noted that the National Labor Relations Board and its Administrative Law Judges frequently treat caucus time as part of the total session time and that the Board generally does not expressly exclude caucus time in its bargaining orders.
The Court acknowledged the concern that Covenant House NY might pretend to caucus to avoid bargaining. It stated that exploiting caucuses could constitute another violation of the National Labor Relations Act and a separate violation of the injunction, which requires bargaining in good faith. The Court directed the National Labor Relations Board to notify it if Covenant House NY appeared to be exploiting its ability to caucus.
The Court rejected Covenant House NY’s remaining objections. It stated that the National Labor Relations Board has broad discretion in choosing remedies and commonly uses cease-and-desist provisions and posted notices. Because the Court had already determined that a bargaining order was the likely remedy, it also would include the cease-and-desist and publication provisions in the written order.
Disposition
The Court ruled that the written injunction order would not exclude caucus time from bargaining-session limits. It would include the cease-and-desist and publication provisions. The National Labor Relations Board was ordered to submit a revised proposed order consistent with the ruling no later than September 3, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.