Longstreet Associates, L.P. v. Bevona
The case involves sixteen security guards dismissed from their jobs at the General Motors Building in Manhattan. Plaintiffs, Pembrook Management, Inc. (PMI), Longstreet Associates, L.P., and Corporate Properties Investors (CPI), sought to enjoin an arbitration proceeding initiated by the Union, Local 32B-32J of the Service Employees International Union. Plaintiffs argued the security guards were employed by a cleaning and maintenance contractor, Temco/Spartan, and thus expressly excluded from coverage under the Collective Bargaining Agreement (RAB Agreement). The Union contended that PMI was a joint employer with Temco/Spartan, meaning the guards were covered by the RAB Agreement's "work preservation provision." The court, after examining factors for joint employer status, found sufficient evidence that PMI had immediate control over the security guards in areas such as hiring, discipline, and day-to-day supervision. Consequently, the court denied the plaintiffs' motion for a preliminary injunction and dissolved the temporary restraining order, ruling that PMI, Longstreet, and CPI were obligated to arbitrate the dispute under the RAB Agreement.