L-EIRI Week Ending April 24, 2026: Labor Union Election Integrity Risk Score 25/100

Every week, labor union election administrators, compliance officers, and legal counsel face a moving target: the regulatory environment, NLRB docket activity, OLMS enforcement posture, and the broader communications landscape all shift in ways that can affect whether a pending or planned election will be defensible. The Labor-Union Election Integrity Risk Index (L-EIRI) is a practical early-warning score designed to track exactly that — not to predict outcomes, but to quantify the operating environment so administrators can take proactive steps before a problem becomes a challenge, a rerun, or a lawsuit.

For the week ending April 24, 2026, the composite L-EIRI score is 25 out of 100. This is the first score of the restarted 2026 baseline, so no week-over-week comparison is applied. Here is what moved each dimension and what it means for unions with elections planned in the near term.

What the L-EIRI Measures

The index tracks five dimensions of election integrity risk, each scored out of 20 points, for a composite maximum of 100. A higher score does not mean an election is invalid — it means the operating environment contains more factors that can create challenges, reruns, objections, delays, or reputational risk. The five dimensions are:

Representation Activity & Disputes — 6/20

Confirmed representation activity was steady but not unusually high during the April 20–24 window, based on visible NLRB docket filings. Four cases illustrate the range of activity election administrators should be aware of.

Etain, LLC (03-RC-385171), filed April 20, involves a five-employee unit in Kingston, New York — a small-unit election that, while modest in scale, carries the same LMRDA and NLRB procedural requirements as any larger election. Providence St. Peter Hospital saw a signed RC petition on April 20 followed by an order to reschedule the hearing on April 24, a reminder that scheduling disruptions are common and that administrators should build buffer time into election timelines. STA of Oregon, Inc. moved quickly from a signed RC petition on April 20 to a stipulated election agreement on April 23 — a three-day turnaround that demonstrates how fast election obligations can crystallize once a petition is filed. Finally, United Insurance Company of America (16-RD-385531) saw a decertification petition filed April 24, a different but equally compliance-sensitive process that requires careful voter eligibility verification and ballot secrecy procedures.

For unions with elections scheduled in the next 60 days, the lesson from this week's activity is straightforward: petition filings and hearing schedules can shift rapidly. Voter lists, eligibility criteria, and ballot procedures should be locked down before a petition arrives, not after.

ULP Election-Interference — 8/20

The highest-scoring dimension this week reflects a meaningful cluster of new CA and CB unfair labor practice filings that could relate to election conditions or workplace organizing pressure. On April 24 alone, visible employer-side CA filings included cases involving G.F. Crane, United States Postal Service, Cigna Healthcare, The Queen's Medical Center, Glacier NW/CalPortland, Designed Metal Connection / Permaswage, CurrentMaster Electric, and Home Express Delivery Service / TEMCO Logistics.

On the union side, CB filings included cases involving National Rural Letter Carriers' Association, UNITE HERE Local 8, APWU South Alabama Area Local 0715, Teamsters Local 777, SPFPA, and IBEW Local 98. The public recent-filings page does not by itself prove the merits of any charge — these are filings, not findings — but the volume and variety of the activity signals that the organizing environment is active across multiple industries and regions.

For election administrators, an elevated ULP filing environment is a direct compliance signal. When CA or CB charges are pending or recently filed, the scrutiny applied to every aspect of the election process — communications, voter access, ballot secrecy, observer rights — increases significantly. Any procedural shortcut that might be overlooked in a quiet period becomes a potential ground for challenge when ULP activity is elevated.

Regulatory & Legal Shifts — 7/20

The main legal development this week was a Fifth Circuit decision requiring the NLRB to reconsider a Starbucks subpoena-related ruling tied to a union election. Reuters reported that the court held the Board had used the wrong legal test and should have evaluated coerciveness under the "totality of the circumstances" standard rather than a narrower framework.

This matters for election integrity beyond the Starbucks context. The totality-of-the-circumstances standard is broader and more fact-intensive than a categorical rule. It means that subpoenas, employee communications, organizer interactions, and even the timing of management communications can all be weighed together when evaluating whether an election environment was free and fair. For unions and employers alike, this decision reinforces the importance of documenting every communication decision made during an organizing campaign or election period.

No new General Counsel memo appeared during the April 20–24 window. The NLRB's GC memo list still showed the most recent 2026 memo as GC 26-03, dated February 27, 2026. Administrators should monitor the GC memo page directly for any new guidance that could affect pending elections.

OLMS Election Compliance — 3/20

No new OLMS voluntary compliance agreement (VCA) was posted during the April 20–24 window. The DOL 2026 VCA page was last updated April 20 and showed two items of note for election administrators.

First, SEIU Local 105 entered a VCA on April 10 involving failed election notice and denied voting rights — two of the most common and most preventable LMRDA violations. Adequate advance notice and unrestricted access to the ballot are foundational requirements under Title IV of the LMRDA, and both are areas where online voting platforms with built-in notification workflows and voter eligibility verification provide a structural compliance advantage over paper-based processes.

Second, APWU Local 232 had a supervised-election deadline of April 24 stemming from a January agreement involving names and addresses printed on ballots — a ballot secrecy violation. Printing identifying information on ballots is a recurring OLMS enforcement trigger. Any election platform that cannot guarantee ballot anonymity is a liability, not a tool.

MDM / Coercive Comms — 1/20

No newly documented misinformation or disinformation campaign and no fresh captive-audience ruling were identified during the April 20–24 window. The score remains above zero because the broader communications environment is legally sensitive wherever ULP filings and court review of coercive-conduct standards are active — as they are this week. Administrators should treat the communications environment as elevated even when no specific incident is documented.

Practical Risk-Mitigation Checklist for This Week

Document neutrality and access rules before petitions arrive. The presence of RC/RD filings and active CA/CB charges makes it important to lock down who can communicate, when, where, and with what scripts. A documented communications policy is far easier to defend than an ad hoc one.

Treat subpoenas, employee statements, and organizer communications as high-risk areas. The Starbucks remand is a direct reminder that coercion standards can turn on how a reasonable employee would perceive the employer's conduct under the totality of the circumstances. Every communication during an active organizing period should be reviewed against that standard.

Clean up voter lists and ballot secrecy procedures now. OLMS's 2026 VCA list shows recurring internal-union election problems around notice, voting rights, eligibility, and ballot secrecy. These are not edge cases — they are the most common grounds for OLMS intervention. Auditing voter eligibility criteria, notification workflows, and ballot anonymity before an election is scheduled is the most cost-effective compliance investment a union can make.

How Votem Helps Unions Manage Election Integrity Risk

The L-EIRI is designed to give election administrators an early-warning signal — but a signal is only useful if you have the tools to act on it. Votem's CastIron® platform is built specifically for the compliance requirements that drive each dimension of this index: LMRDA Title IV secret ballot requirements, OLMS-defensible audit trails, voter eligibility verification, advance notice workflows, and ballot anonymity by design.

When the operating environment is elevated — as it is this week across ULP activity, appellate court developments, and OLMS enforcement — the difference between a defensible election and a challenged one often comes down to documentation. CastIron produces a complete compliance documentation package for every election, including timestamped voter notifications, eligibility verification records, ballot chain-of-custody logs, and certified results — everything an administrator needs to respond to an OLMS inquiry or an election challenge.

If you have an election scheduled in the next 90 days and the current environment has raised questions about your procedures, book a 15-minute compliance review with the Votem team. We will walk through your specific situation and tell you exactly where your current process is defensible and where it is not.