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Union Busting @ Spring Creek Rehabilitation

TL;DR

  • A nursing home company called Spring Creek bought a facility in 2021 and immediately told its workers’ union to get lost, refusing to bargain over wages, benefits, or any terms of employment.
  • The National Labor Relations Board charged Spring Creek with illegal union-busting; instead of showing up and defending itself, the company ran to federal court to shut the entire NLRB process down.
  • Spring Creek’s legal argument: the judges at the NLRB can’t be fired easily enough by the President, so the whole proceeding is unconstitutional and should be blocked before it even reaches a verdict.
  • The Third Circuit Court of Appeals unanimously rejected this maneuver, ruling that the Norris-LaGuardia Act strips courts of the power to grant Spring Creek the injunction it wanted.
  • The case now returns to the lower court, the NLRB hearing has already occurred, and the workers’ union is still waiting to find out whether their employer will ever be forced to bargain with them in good faith.

The legal strategy Spring Creek used is the same playbook corporations across America are running to kill worker protections at the source. The corporate roles and the regulatory watchlist are in “What Now?” — and the implications stretch far beyond one nursing home.

A nursing home company bought a facility, looked its workers’ union dead in the face, declared it would set wages and conditions however it wanted without negotiating, and then spent years in federal court trying to make sure no government body could ever hold it accountable for doing so.

They Bought the Nursing Home and Told the Workers’ Union to Drop Dead

How a Healthcare Company Weaponized Constitutional Law to Dodge Its Workers

In November 2021, Spring Creek Rehabilitation and Nursing Center LLC purchased a skilled nursing facility from a prior operator called Amboy Nursing and Rehabilitation Center. The workers at that facility had been represented for years by 1199SEIU United Healthcare Workers East, one of the most prominent healthcare worker unions in the country. Before the ink dried on the sale, Spring Creek sent the union a letter with a simple message: we are not bound by any collective bargaining agreement, we will set the terms of employment ourselves, and we do not intend to bargain with you.

That move was not a grey area. Refusing to bargain collectively and in good faith with the exclusive representative of your workers is a textbook violation of Section 8(a)(5) of the National Labor Relations Act. The union had already filed an unfair labor practices charge against the prior owner, Amboy, back in August 2021, when they learned the sale was coming. In May 2023, the union amended that charge to add Spring Creek as a party.

The NLRB issued a formal complaint against Spring Creek in May 2024, followed by an amended complaint two months later. Spring Creek was ordered to appear at a hearing before an Administrative Law Judge on September 10, 2024. Rather than show up and make its case, the company filed a lawsuit in federal court demanding the entire proceeding be stopped before it could begin.

“Spring Creek alleged it was free to set terms and conditions of employment unilaterally without bargaining with the Union.”

The Shell Game: Turn a Labor Fight Into a Constitutional Crisis

Spring Creek’s legal theory was, on its surface, creative. The argument went like this: NLRB Administrative Law Judges have certain job protections that make them difficult to fire, and because the President can’t easily remove them, their authority is unconstitutional under the separation of powers doctrine. Therefore, the entire proceeding should be blocked by a federal court injunction before any decision gets made.

This is the corporate equivalent of getting pulled over for running a red light and then arguing the traffic court itself is illegal so the ticket shouldn’t count. The constitutional challenge had nothing to do with whether Spring Creek actually broke the law. It was purely a procedural hand grenade thrown to blow up the process before a verdict could be reached.

The District Court denied Spring Creek’s request for a preliminary injunction, finding it had not demonstrated it would suffer irreparable harm. The hearing went forward. Spring Creek then appealed, still trying to get a court to stop the NLRB judge from issuing any final decision at all.

The Third Circuit Slams the Door

The Third Circuit Court of Appeals ruled against Spring Creek in a December 3, 2025 opinion. The court’s majority held that the case falls squarely within the Norris-LaGuardia Act, a 1932 law designed specifically to prevent federal courts from being used as a weapon against workers and their unions. The Act strips courts of jurisdiction to issue injunctions in cases that “involve or grow out of” a labor dispute, and the court found that Spring Creek’s entire lawsuit grew directly out of its refusal to bargain with its workers.

The ruling explicitly rejected the reasoning used by the Fifth Circuit in a similar case involving SpaceX, which had found that constitutional challenges to the NLRB’s structure fall outside the Norris-LaGuardia Act’s scope. The Third Circuit disagreed, holding that Congress made the definition of “labor dispute” intentionally broad and never carved out an exception for challenges to agency structure.

In a separate concurring opinion, a third judge would have dismissed the case on different grounds entirely: Spring Creek simply never demonstrated any real, concrete injury. Challenging the constitutionality of removal protections requires showing that those protections actually caused you harm. Spring Creek could not make that showing.

Timeline of Events: Spring Creek vs. Its Workers

Jun 2017 CBA Takes Effect Jun 2020 CBA Expires Nov 2021 Spring Creek Buys Facility May 2023 Union Adds Spring Creek May 2024 NLRB Files Formal Complaint Sep 2024 ALJ Hearing Goes Forward Dec 2025 3rd Circuit Rules vs. Spring Creek Key events in the Spring Creek labor dispute, 2017–2025

The Non-Financial Ledger: What the Workers Actually Lost

The nursing home workers at this facility did not wake up one day and decide to unionize on a whim. They were already organized. They already had a collective bargaining agreement. They had negotiated wages, welfare fund payments, vacation time, sick leave, holidays, and other monetary protections through their union over years of hard work at the bargaining table. That agreement had been in place since June 2017. When it expired in June 2020, the workers had every reasonable expectation that any new owner of their workplace would honor the successor provisions that required the facility’s obligations to carry over.

Spring Creek walked in and erased all of that in one letter. The company declared, before it even formally took ownership, that it would not assume the collective bargaining agreement and that it would set wages and working conditions entirely on its own terms. For nursing home workers, this is not an abstract grievance. These are people who clean wounds, turn bedridden patients to prevent pressure sores, administer medications, manage feeding tubes, and absorb the emotional weight of watching people die. Their wages, their healthcare coverage, their ability to take a sick day without fear: all of it was stripped away by a corporate declaration issued before they even knew their building had changed hands.

The Norris-LaGuardia Act, which ultimately decided this case, was passed in 1932 precisely because workers had spent decades watching federal courts grant emergency injunctions to employers at the drop of a hat. Judges would issue restraining orders against strikes, picket lines, and union organizing drives often within hours of an employer filing a complaint, and workers would lose their leverage before they could mount any meaningful response. Congress wrote the Act to end that era. The fact that Spring Creek tried to use a federal court injunction to stop the NLRB from even holding a hearing is a direct echo of the exact corporate behavior the law was designed to prevent.

What the legal filings cannot capture is the grinding, demoralizing experience of working in a facility where the people who sign your checks have publicly announced they do not consider themselves bound by any negotiated agreement with you. For four-plus years, from the 2021 takeover through the December 2025 appeals court ruling, these workers existed in a legal limbo where their employer was simultaneously subject to an unfair labor practices complaint and actively working in court to make sure that complaint could never be adjudicated. That is not a neutral administrative process. That is a power play designed to exhaust and outlast the people on the other side of the dispute.

Legal Receipts: They Said It Out Loud

The Company’s Position, in Black and White

“Spring Creek alleged it was free to set terms and conditions of employment unilaterally without bargaining with the Union.”

— Third Circuit Court of Appeals, describing Spring Creek’s own stated position, December 3, 2025
“It alleges that Spring Creek refused to ‘bargain collectively and in good faith with the exclusive collective-bargaining representative of its employees in violation of Section 8(a)(1) and (5)’ of the NLRA.”

— Third Circuit Court of Appeals, summarizing the NLRB complaint, December 3, 2025
“If the District Court enjoined the NLRB’s administrative proceedings, it would prevent the tribunal tasked by Congress with deciding the Union’s unfair labor practices charge from resolving the merits of the case. That would put a thumb on the scale for Spring Creek in the underlying dispute, precisely the kind of ‘judicial interference in management-labor relations’ the Act’s anti-injunction provisions seek to prevent.”

— Third Circuit Court of Appeals, majority opinion, December 3, 2025
“It could not have brought this action but for the underlying dispute.”

— Third Circuit Court of Appeals, on the relationship between Spring Creek’s lawsuit and the underlying labor dispute, December 3, 2025
“Congress made the definition of ‘labor dispute’ broad because it wanted it to be broad.”

— Third Circuit Court of Appeals, quoting the Supreme Court in Burlington Northern Railroad Co. v. Brotherhood of Maintenance of Way Employees (1987), and applying it to Spring Creek’s case
“The primary contention was that Amboy violated the expired agreement’s successor provisions by selling the facility to Spring Creek without requiring it to ‘be personally responsible for all unpaid wages, welfare fund payments, vacations, holidays, sick leave and all other monetary items.'”

— Third Circuit Court of Appeals, describing the union’s original 2021 charge, December 3, 2025
“Spring Creek’s inability to allege adequately that it was harmed by any restrictions on removing NLRB members or Administrative Law Judges is fatal to its Article III standing.”
— Concurring Judge Montgomery-Reeves, December 3, 2025

Societal Impact Mapping

Economic Inequality: The Corporate Playbook to Make Accountability Impossible

What Spring Creek did is not unique to one nursing home in New Jersey. The strategy it deployed, filing a federal lawsuit to block an NLRB proceeding on constitutional grounds before any decision is reached, is a coordinated corporate legal tactic that multiple companies are running simultaneously. The Third Circuit’s own opinion cites cases involving Amazon (filed February 2025), a casino resort operator (filed September 2025), SpaceX (decided by the Fifth Circuit), and multiple hospital and healthcare systems. These are not coincidental lawsuits. This is an organized effort to gut the NLRB’s enforcement power by arguing that the agency’s structure is unconstitutional before it ever rules against a company.

The economic stakes for workers are enormous. When a company successfully delays or derails an NLRB proceeding, it buys itself additional years of operating without a union contract. Every month without a contract is a month where wages can stay lower, hours can stay longer, sick leave can be denied, and workers have no collectively bargained recourse. For nursing home workers specifically, who are already among the lowest-paid caregivers in the healthcare sector, that delay translates directly into economic harm that compounds over time.

The Norris-LaGuardia Act ruling is a significant check on this tactic, at least in the Third Circuit. But the Fifth Circuit ruled the opposite way in the SpaceX case. That circuit split means the same legal maneuver produces different outcomes depending on which state a company operates in. In states covered by the Fifth Circuit (Texas, Louisiana, Mississippi), corporations can potentially still use federal courts to freeze NLRB proceedings. Workers in those states have fundamentally weaker legal protection right now than workers in states covered by the Third Circuit.

The Norris-LaGuardia Act itself was created in 1932 to stop exactly this kind of wealth-powered legal interference. The Third Circuit explicitly acknowledged that the Act’s “broader goal” is to “prevent judicial interference in management-labor relations.” The fact that corporations are successfully reviving this tactic nearly a century later, and that courts are splitting on how to respond, demonstrates how durable the structural economic inequality between employers and workers really is.

Public Health: Who Actually Pays When Nursing Home Workers Have No Contract

Spring Creek operates a skilled nursing facility. The workers there are not office employees debating vacation accrual policy. They are certified nursing assistants, licensed practical nurses, dietary aides, housekeeping staff, and rehabilitation technicians providing direct care to some of the most vulnerable people in society: the elderly, the post-surgical, the disabled, and the dying. When an employer unilaterally sets working conditions without union input in this environment, the people who suffer most are the patients.

Staffing levels in nursing homes are directly tied to patient outcomes. Lower wages mean higher turnover, which means less experienced staff on the floor, which means more falls, more medication errors, more infections, and more hospitalizations. The workers’ union, 1199SEIU United Healthcare Workers East, represents healthcare workers across the sector specifically because decades of evidence show that collective bargaining produces better staffing ratios and better patient care. When Spring Creek stripped the union contract and declared it would set terms unilaterally, it was not just harming workers. It was degrading the conditions for the patients in its care.

How Many Companies Filed to Block NLRB Proceedings on Constitutional Grounds (cases cited in this ruling)

0 1 2 3 4 5 3 3rd Circuit 1 5th Circuit 2 D.C. District 2 9th Circuit Cases Cited (count) Cases specifically cited in the Third Circuit opinion attempting to block NLRB proceedings on constitutional grounds

What Now? Here’s Where the Accountability Actually Lives

The Corporate Roles in This Story

The source documents name Spring Creek Rehabilitation and Nursing Center LLC as the corporate actor. Its parent structure and specific ownership are [REDACTED – Not in Source]. The named legal representatives for Spring Creek are Louis J. Capozzi, Jr. and Brandon S. Williams of Capozzi Adler, based in Harrisburg, Pennsylvania.

Regulatory Watchlist

These are the bodies with direct authority over Spring Creek and over the broader pattern of corporate NLRB-blocking this case is part of:

NLRB DOJ OSHA CMS (Centers for Medicare & Medicaid Services) State Labor Boards 1199SEIU United Healthcare Workers East

The NLRB is the only federal agency whose entire purpose is to enforce workers’ right to organize and bargain collectively. It is also the agency under the most sustained legal and political attack right now from corporate actors running this same constitutional-challenge playbook. Watch what happens to its enforcement budget, its staffing, and its independence.

What You Can Actually Do

If you or someone you know works in a nursing home, assisted living facility, or any healthcare setting, connect with your regional 1199SEIU chapter or the nearest healthcare workers’ union. If your facility changes ownership, the union successor clause is the most important clause in any collective bargaining agreement. Know it. Demand it be enforced before the new owner sets foot on the property.

Support organizations that provide free legal assistance to workers facing unfair labor practices charges. Many communities have workers’ rights centers and labor law clinics that can advise workers on their rights under the NLRA without charging attorney fees. Mutual aid within workplaces, workers supporting each other through job actions and legal fights, is what outlasts any individual lawsuit. The Norris-LaGuardia Act won this round because workers in 1932 fought to put it on the books. The same principle applies now.

The source document for this investigation is attached below.

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Aleeia
Aleeia

I'm Aleeia, the creator of this website.

I have 6+ years of experience as an independent researcher covering corporate misconduct, sourced from legal documents, regulatory filings, and professional legal databases.

My background includes a Supply Chain Management degree from Michigan State University's Eli Broad College of Business, and years working inside the industries I now cover.

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