Goulden v. Oliver Et Al.

How later courts describe this case

• finding that “[o]nce a violation is demonstrated, the moving party need show only that there is some reasonable likelihood of future violations” under Section 6c of the Act
• approving the American Law Institute rule allowing venue in any district in which a substantial part of the events or omissions giving rise to the claim occurred
• great deference given to the inferences drawn by the Board from testimony credited by the ALJ
• burden rests on employer to undertake initial steps toward accommodation; employer cannot excuse failure to accommodate by pointing to deficiencies in employee’s suggested accommodation
• employee discontent, turnover, union inactivity, low union membership, financial difficulties of the union, and bargaining history were insufficient individually and cumulatively, where none of the evidence was wholly referable to a decline in union support
• “As required to support such relief, these respondents alleged (and petitioner did not deny