Court orders Garten Trucking to bargain with union despite 2021 election loss

The U.S. Court of Appeals for the Fourth Circuit ruled Feb. 19, 2026, that Garten Trucking must negotiate a contract with the Association of Western Pulp and Paper Workers, despite the union losing a representation vote. The court upheld an NLRB "Gissel" order, determining that management’s coercive conduct—including threats regarding paper mill contracts and disciplining employees—was pervasive enough to require bargaining. The union lost the election 65-30 in August 2021 after securing 61 authorization cards. The ruling affirms that employer misconduct can override election results in labor disputes.