United States Court of Appeals,
Second Circuit.
SDBC HOLDINGS, INC., f/k/a Stella D‘oro Biscuit Co., Inc., Petitioner–Cross–Respondent,
Background: Employer petitioned for review of order of National Labor Relations Board (NLRB), 355 NLRB No.
158, concluding that employer engaged in unfair labor practices principally by declining to permit the union to re-
tain a copy of the company’s audited financial statement during the course of collective bargaining. The NLRB
cross-petitioned for enforcement.
Jose A. Cabranes, Circuit Judge, filed a concurring opinion.
West Headnotes
231Hk1118 k. Particular subjects of disclosure. Most Cited Cases
Under the NLRA, an employer has no duty to turn over financial condition information during the collective
bargaining process unless the union can demonstrate a specific need; and no such need for financial information
exists where an employer has professed only an unwillingness to meet the union’s demands, as opposed to, expressly