Fourth Circuit remands salting case for more reasoning (or seasoning) from NLRB

In NLRB v. Forsyth Electrical Co., Inc., the Fourth Circuit in a per curiam decision for Judges Widener and Luttig remanded the case to give the NLRB a chance to elaborate further on the reasoning underlying its decision that the employer had unlawfully discriminated against three union "salts" by failure to reinstate them despite their unconditional offer to come back to work. Judge Niemeyer in dissent noted briefly his view that the proper disposition of the case was simply to deny the NLRB's petition for enforcement and put an end to the case without further proceedings.