Judge Finds Amazon Violated Labor Law at Multiple Facilities but Upholds Some Key Policies

Written from court documents

WASHINGTON — July 24, 2025

An administrative law judge for the National Labor Relations Board has ruled that Amazon.com Services LLC violated federal labor law in multiple instances by restricting union-related activities and threatening or calling police on workers engaged in organizing efforts at warehouses in New York, Missouri, and Illinois.

The ruling, issued under case JD-63-25, stems from complaints filed across multiple regions and facilities — including Albany (ALB1), Chicago, Staten Island (JFK8), and St. Louis (STL8) — and sheds light on how Amazon responded nationally after a union victory at its Staten Island warehouse.

In April 2022, the Amazon Labor Union (ALU) won a landmark election at the JFK8 facility in Staten Island — the first successful union vote at any U.S. Amazon warehouse. In the months that followed, Amazon rolled out a new nationwide off-duty access policy that prohibited employees from remaining on company property outside of their work shifts — a move widely viewed by labor organizers as an attempt to curb further union momentum.

The judge found that while Amazon had legitimate safety concerns to justify the policy — including a deadly tornado at a St. Louis-area facility that killed six workers — the company violated the law by using the policy to suppress protected union activity in non-work areas such as parking lots. Managers at facilities in Albany and St. Louis were found to have unlawfully threatened or removed workers and union leaders engaged in organizing, including calling police on former JFK8 employee Gerald Bryson, a fired Amazon worker still considered a statutory employee under labor law.

Christian Smalls, president of the ALU and a former JFK8 worker, also faced intervention from Amazon’s security teams when he traveled to the ALB1 warehouse in Albany to support union efforts. The judge ruled that Amazon’s handling of those events violated workers’ rights under Section 8(a)(1) of the National Labor Relations Act.

The ruling underscores how Amazon has worked to contain the spread of the ALU beyond Staten Island. ALU-backed campaigns in Albany and at the LDJ5 facility in Staten Island were ultimately unsuccessful, but organizers claimed Amazon used surveillance, policy enforcement, and law enforcement to chill support.

Judge Charles J. Muhl also ruled that Amazon’s solicitation policy was unlawfully broad and confusing, potentially discouraging employees from engaging in legally protected organizing activities during non-work time.

However, the judge upheld Amazon’s right to restrict off-duty access to work areas for safety and security purposes, and found no evidence that Amazon wrongfully fired JFK8 worker Connor Spence solely for union activity. A request to invalidate the Albany election based on Amazon’s conduct was denied, with the judge calling the violations “de minimis” and insufficient to change the outcome of the vote, which the union lost by a wide margin.

The decision marks a mixed outcome: while it recognizes Amazon’s right to manage safety through workplace policy, it also affirms that the company crossed legal lines in trying to stifle union activity, particularly efforts tied to the Staten Island-based Amazon Labor Union.

The ruling may be reviewed by the full National Labor Relations Board and could shape future disputes as organizing efforts continue at Amazon warehouses across the country.

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