Atrium of Princeton, LLC v. National Labor Relations Board, 684 F.3d 1310

Atrium at Princeton owns the nursing home Pavilions at Forrestal and was involved in bargaining with SEIU 1199 New Jersey Health Care Union.
The National Labor Relations Board found Atrium committed unfair labor practices in connection with negotiations for a new CBA.
The Board concluded Atrium did not bargain in good faith because negotiations were not at impasse when Atrium refused further bargaining.
The dispute centers on whether subsequent events broke any impasse, particularly the Fund's cancellation of health benefits.
Atrium argued the Fund acted as the Union’s agent and that the impasse was broken by the Fund’s actions; the Board rejected both defenses.
The court ultimately upheld the Board’s order and enforcement, denying Atrium’s petition for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the Fund act as the Union’s agent?	Atrium asserts Union control caused cancellation.	Board found no Union control or agency.	No agency; Board’s finding supported.
Was any bargaining impasse broken by the health-plan cancellation?	Impasse persisted; no productive bargaining.	Cancellation altered negotiations, breaking impasse.	Cancellation broke any impasse; Board’s conclusion sustained.

NLRB v. Amax Coal Co., 453 U.S. 322 (U.S. 1981) (trustees' fiduciary duty prevents union agency finding)
Serramonte Oldsmobile, Inc. v. NLRB, 86 F.3d 227 (D.C. Cir. 1996) (impasse and changed circumstances; evolving bargaining duties)
Mail Contractors of America v. NLRB, 514 F.3d 27 (D.C. Cir. 2008) (impasse; changed circumstances may permit unilateral action)
Laurel Bay Health & Rehabilitation Center v. NLRB, 666 F.3d 1365 (D.C. Cir. 2012) (union flexibility vs. impasse; control evidence)
Wayneview Care Center v. NLRB, 664 F.3d 341 (D.C. Cir. 2011) (substantial evidence for no impasse due to union concessions)