This Recent Development will examine the substance and implications of the latter aspect of Pittsburgh Plate Glass, although it is only dictum in the case. The third ground of the Board's conclusion regarding retirement benefits was really only a general reiteration of the first two. It is therefore apparent that that ground is dependent upon the validity of either or both of the other two bases of the Board's conclusion.
Michigan Law Review,
Labor Law--Collective Bargaining--The Retirement Benefits of Retired Employees Are a Mandatory Subject of Bargaining Because Retirees Are "Employees" Under the NLRA and Because Active Employees Have an Interest in Such Benefits--Pittsburgh Plate Glass Company, Chemical Division,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol68/iss4/7