In NLRB v. Kodiak Electric Co., Inc., the Fourth Circuit in a per curiam opinion for the panel of Judges Traxler and Shedd and Senior Judge Hamilton granted the NLRB's petition for enforcement where a unionized electrical contractor was not too subtle in establishing and sending work to a non-union company in his wife's name.
My favorite part of the facts is this paragraph:
"In March of 1999, Timothy Demski and a Porter project manager, Peter Robey, discussed manpower problems on the Kodiak Line projects. Demski asked Robey to 'write the dirtiest, nastiest letter that [Porter] could' to terminate the contract with Kodiak Electric. J.A. 39. He also told Robey that Kodiak Electric had a "sister company" that did not have the same manpower constraints and could easily absorb the workload that Kodiak Electric had proved unable to handle. J.A. 39. On March 17, Robey sent a letter to Kodiak Electric terminating its contract for the work at the Rockview project. That same day, Porter contracted with Kodiak Line to complete the remainder of the electrical work at a price that reflected the balance of the original contract with Kodiak Electric."
The record does not say how dirty or nasty was the letter written by the project manager at the union contractor's request.