🗞️ Shell Game at the La Quinta: How a New Jersey Hotel Tried to Swap Out Its Union Obligations

On April 22, 2026, the National Labor Relations Board issued a default judgment against Rollo Hospitality LLC, doing business as Ramada by Wyndham in Fairfield, New Jersey, finding the company liable for multiple serious violations of the National Labor Relations Act. The case, brought by the Hotel and Gaming Trades Council, AFL-CIO, centered on allegations that SAAS Hotels NJ LLC, the operator of a La Quinta Inn & Suites at the same address, created Rollo in March 2023 as a corporate alter ego with a single purpose: to walk away from its collective bargaining obligations before the ink on the old contract had fully dried.

The Board found that SAAS established Rollo as what labor law calls a "disguised continuance" of itself, sharing substantially identical management, ownership, operations, equipment, and customers. Those are the hallmarks of the NLRB's alter ego doctrine, a legal theory designed to prevent employers from shedding union obligations by simply hanging a new sign on the door. The timing left little to the imagination. The Greater Regional Industry-Wide Agreement, the collective bargaining contract covering housekeeping, front office, food and beverage, and engineering staff, was set to expire on March 31, 2023. Rollo was incorporated on March 3, just weeks before, and wasted little time unwinding the labor relationship once the agreement lapsed.

The conduct that followed was broad and, according to the Board, unlawful on multiple fronts. Managers told employees outright that they were no longer represented by the union, a statement the Board found implied that continued support for the union was futile. Workers were threatened with job loss and business closure if they kept backing the union, and were prohibited from discussing wages or working conditions with one another, in violation of basic rights guaranteed under Section 7 of the National Labor Relations Act. On the contractual side, the company unilaterally overhauled sick leave policies, changed probationary period terms, increased housekeeping room quotas, and subcontracted bargaining-unit work, all without notifying the union or bargaining to impasse. Dues collected from employees under valid checkoff authorizations were never remitted to the union, and the union was denied access to the property entirely. Five employees were discharged between March and July 2023 in what the Board found was retaliation for union membership and concerted activity: Larissa Tosi, Kim Cochran, Milagros Payano, Jose Bernal, and Marleny Guerra.

The case against SAAS Hotels itself, the alleged originating entity, did not fare as cleanly for the General Counsel. The Board denied the motion for default judgment against SAAS, finding that federal labor law's service requirements had not been met. Papers were emailed only to Jessica Sider, a co-owner of Rollo, with no apparent effort to reach Anurag Gupta or Anita Gupta, who are identified in the complaint as owners of SAAS. Notably, Anurag Gupta is also listed as an owner of Rollo, yet no attempt to serve him in that capacity appears in the record either. Without proper service on SAAS, the Board declined to enter findings against it, leaving that exposure unresolved and the matter open for future proceedings.

The remedies ordered against Rollo are extensive. The company must offer full reinstatement to all five discharged employees within 14 days, make them whole for lost earnings and other foreseeable financial harms with interest, rescind every unilateral change to working conditions, return to the bargaining table in good faith, and post a formal notice to employees of their rights. The decision was issued by Chairman James R. Murphy and Members David M. Prouty and Scott A. Mayer, a panel confirmed by the Senate in December 2025. The Board applied the remedy standard established in Thryv, Inc., 372 NLRB No. 22 (2022), which requires employers to compensate workers not only for lost wages but for other direct and foreseeable pecuniary harms flowing from an unlawful discharge. Chairman Murphy and Member Mayer noted in a footnote that they were open to reconsidering that precedent in a future proceeding but applied it here in the absence of a three-member majority to overrule it.

The case is one of several overlapping NLRB proceedings tied to the same Fairfield property. A subsequent charge filed in March 2025, Case 22-CA-362910, named a third entity, Shree Krishna Krup LLC, as a potential additional alter ego of SAAS and Rollo. That case was withdrawn in August 2025, but its filing raises questions about whether the corporate restructuring extended further than the Board's current order reaches.

Key Points

• Alter ego scheme: SAAS Hotels allegedly incorporated Rollo Hospitality in early March 2023, weeks before the union contract expired, in what the Board found was a deliberate attempt to shed collective bargaining obligations under the GRIWA agreement.
• Default judgment against Rollo only: Because neither company answered the complaint, the Board deemed the allegations admitted as to Rollo. The motion against SAAS was denied because the General Counsel failed to demonstrate proper service on its owners.
• Five workers ordered reinstated: Larissa Tosi, Kim Cochran, Milagros Payano, Jose Bernal, and Marleny Guerra were discharged between March and July 2023 for union activity and must be offered their jobs back within 14 days of the order.
• Sweeping contract rollbacks: Beginning in April 2023, Rollo unilaterally changed sick leave, probationary periods, room quotas, and subcontracting rules, and stopped remitting union dues collected from employees.
• Information request: The Board ordered Rollo to furnish most of the union's August 2023 information request but carved out one item — ownership interests in unrelated hotels — finding it not presumptively relevant to the union's bargaining role.
• Board applies Thryv remedy standard: The panel applied the remedy framework from Thryv, Inc. (2022), which covers foreseeable financial harms beyond back wages. Two of the three members noted openness to reconsidering that precedent but applied it for lack of a majority to overrule it.
• Possible third alter ego: A 2025 charge named Shree Krishna Krup LLC at the same Fairfield address as a potential further alter ego, though that case was subsequently withdrawn.

Primary Source Author: Chairman James R. Murphy, with Members David M. Prouty and Scott A. Mayer

Primary Source: SAAS Hotels NJ LLC d/b/a La Quinta Inn & Suites Fairfield and Rollo Hospitality LLC d/b/a Ramada by Wyndham, 374 NLRB No. 99 (April 22, 2026)

Primary Source Link: https://www.nlrb.gov/case/22-CA-315658

Supplemental Links

• NLRB Case Docket 22-CA-315658
• NLRB Case Docket 22-CA-323960
• NLRB Related Case 22-CA-362910 (Shree Krishna Krup LLC)
• Hotel and Gaming Trades Council, AFL-CIO
• NLRB Alter Ego Doctrine Overview, Michigan Law Review
• Hotel Industry NLRB Uncertainty, Hotel Dive
• What a Stalled NLRB Means for Hotel Employers, CoStar
• Hotel and Gaming Trades Council NJ Expansion, NJ AFL-CIO