John D. Doyle 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 denied Covenant House NY’s motion to pause an injunction requiring it to bargain during its appeal.
Covenant House NY remains subject to the previously issued injunction requiring eight hours of good-faith bargaining each month while its appeal proceeds. The ruling also affects the National Labor Relations Board and the Union involved in the bargaining, which the court said would be harmed by further delay.
What happened
In Doyle v. Covenant House NY, the National Labor Relations Board’s regional director asked the court to keep an earlier injunction in effect while Covenant House NY appeals. That injunction requires Covenant House NY to bargain in good faith for eight hours each month.
Covenant House NY argued that it was likely to win its appeal because two personnel were managers under federal labor law. It also argued that interviews of those personnel violated its right to have counsel present. The court rejected both arguments, explaining that Covenant House NY had not presented evidence at the administrative hearing showing that the personnel were managers.
Judge Abrams denied Covenant House NY’s motion to stay the injunction pending appeal. She found that Covenant House NY would suffer little harm without a stay, while delaying bargaining would harm the Board, other interested parties, and the public interest.
The detailed version
- John D. Doyle v. Covenant House NY · No. 1:25-cv-03642
- Ronnie Abrams
- Sept. 9, 2025
Background
On August 13, 2025, the Court orally granted the Petitioner’s request for an injunction under Section 10(j) of the National Labor Relations Act. The Court issued a written order granting the injunction on September 5, 2025. Covenant House NY appealed and then moved to stay—that is, temporarily suspend—the injunction while the appeal proceeds.
The injunction requires Covenant House NY to bargain in good faith for eight hours each month. The order addressed only whether that injunction should be suspended pending appeal; it did not decide the appeal itself.
The Court’s Analysis
Under Federal Rule of Civil Procedure 62(c), a district court may suspend an injunction pending appeal. Courts consider four factors: whether the party seeking the stay is likely to win on appeal, whether it will suffer irreparable harm without a stay, whether a stay would substantially harm other interested parties, and where the public interest lies.
The Court found that Covenant House NY was not likely to succeed on its argument that two personnel were “managers” under the National Labor Relations Act. Covenant House NY had attempted to treat its own statement in its answer as binding on the Petitioner, but the Court explained that a party cannot use its own admission to bind its opponent. The Court also rejected Covenant House NY’s argument that the Petitioner had admitted the personnel were managers, finding that the Petitioner’s pleading did not say that.
The Court separately addressed Covenant House NY’s argument concerning alleged violations of its right to counsel during interviews with the two personnel. The Court stated that, even if the interviews violated that right, the remedy would be to exclude statements from the interviews. Covenant House NY would still have had to present evidence at the administrative hearing that the personnel were managers, and the Court found that it had entirely failed to do so.
Ruling
Judge Ronnie Abrams found that the remaining factors also favored the Petitioner. The requirement to bargain for eight hours each month posed, at most, minimal harm to Covenant House NY. Suspending the injunction would instead harm the Petitioner, other interested parties, and the public interest by further delaying the Union’s good-faith efforts to bargain with Covenant House NY.
The Court denied Covenant House NY’s motion for a stay pending appeal and directed the Clerk of Court to terminate the motions listed at docket entries 54 and 55.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.