Since 1978, the International Association of Machinists, Lodge 1899, has been the certified bargaining representative of certain food service employees of Marriott In-Flite Services.
In 1980, without bargaining with the union, Marriott unilaterally bestowed an 11 percent wage increase and an additional holiday on these employees. Marriott contended that it had honestly doubted that the Machinists represented a majority of these employees since the fall of 1979, and therefore it did not bargain with the Machinists.
The Machinists alleged that the granting of wage and benefit increases without bargaining was a violation of Section 8(a)(5) and (1) of the NLRA. Decide.