Executive Summary: The Fourth Circuit recently upheld a finding of the National Labor Relations Board (NLRB) that four employees were not supervisors, even though each employee oversaw the daily work of between 22 and 40 workers. The Fourth Circuit acknowledged that there was some evidence of supervisory authority but deferred to the NLRB’s conclusions that the employees at issue were not supervisors. See Pac Tell Grp., Inc. v. NLRB, No. 15-1111, unpublished (Dec. 23, 2015).
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