REPORTED


  IN THE COURT OF SPECIAL APPEALS


            OF MARYLAND



              No. 201


        September Term, 1998


___________________________________
                     





             GIANT FOOD, INC.



    



                  v.




 DEPARTMENT OF LABOR, LICENSING AND 
             REGULATION ET AL.


___________________________________


        Eyler,
     Bishop, John J.
        (Ret., specially assigned),
     Fischer, Robert F.
           (Ret., specially assigned),
                     JJ.
____________________________________


     Opinion by Fischer, J.
____________________________________


Filed: January 4, 1999


          In this appeal, Giant Food, Inc. ("Giant"), the


appellant, challenges a determination by the Board of Appeals of


the Department of Labor, Licensing and Regulation ("the Board of


Appeals" or "the Board"), as affirmed by the Circuit Court for


Montgomery County.  The determination permits truck drivers who


engaged in a strike against Giant from December 15, 1996 to


January 18, 1997, as well as other workers who participated in a


sympathy strike, to collect unemployment benefits.  Appellees are


the various claimants as well as the Board of Appeals.


                              FACTS

          Giant operates 174 grocery stores in Maryland,


Delaware, Pennsylvania, Virginia, New Jersey, and the District of


Columbia.  The stores are supplied primarily by way of Giant's


two warehouse/distribution centers, one located in Landover,


Maryland and the other located in Jessup, Maryland.  Giant also


operates its own beverage plant and ice cream plant in Jessup,


its own dairy in Landover, and its own bakery in Silver Spring.


          The evidence presented before the Board of Appeals


established that Local 639 of the Teamsters Union represents the


truck drivers who drive tractor trailers from the


warehouse/distribution centers to the stores and who jockey


trailers around inside Giant's facilities.  It was local 639 that


went on strike against Giant on December 15, 1996.  Based on the


facts before it, the Board determined that members of the


following union locals "actively participated in the Local 639


                                      - 2 -

strike, by refusing to come to work and/or picketing in sympathy


with 639":


                   - Teamsters Local 730, which represents,
              among others, warehousemen, bakery sanitors,
              cafeteria and vending workers, ice plant
              workers, and salvage workers,


                   - Teamsters Local 67, which represents
              workers at the beverage plant,


                   - Teamsters Local 355, which represents
              truck drivers who deliver pharmaceuticals,


                   - Teamsters Local 922, which represents,
              among others, garage helpers and facility
              maintenance workers,


                   - Teamsters Local 246, which represents
              dairy workers, ice cream workers, bakery
              drivers, and depot workers,


                   - Local 1486 of the International
              Association of Machinists, which represents
              garage mechanics, and


                   - Local 118 of the Bakery, Confectionery
              and Tobacco Workers International Union,
              which represents the bakers at the Silver
              Spring bakery as well as the in-store bakers.


              As a result of the strike, Giant was unable to supply


its grocery stores by way of its warehouse/distribution centers. 


Instead, it used outside wholesalers and suppliers to stock the


stores.  The ice cream plant, beverage plant, and dairy were shut


down for the duration of the strike.  The bakery was closed


initially but reopened after three weeks, when the bakery workers


returned.  Giant estimated that it lost about $4 million in


manufacturing profits.  The Board found that the evidence before


it established that, during the period of the strike,


                               - 3 -

                (1) Giant incurred increased costs of
           approximately $3.9 million [to replace goods
           it ordinarily manufactured] . . . ;


                (2) Giant experienced an overall
           decrease in customer count that ranged from
           6% to 10%, depending on how it is calculated
           . . . ;


                (3) Giant experienced a decrease in
           aggregate sales of food and drugs of 14.82%
           . . . .


           The Board nevertheless determined that Giant had failed


to establish that a "stoppage of work" necessary to disqualify


the strikers from receiving unemployment benefits had occurred. 


The circuit court affirmed and commented, inter alia,: "I cannot


say that the Board who is charged with the responsibility of


interpreting the law at first is clearly erroneous on the law,


that one could not come to that result."  The court added: "[T]he


law has always been in administrative proceedings, that the gloss


put on a statute by the administrator, unless it is clearly


wrong, should be followed."


                               ISSUES

           Giant contends that the circuit court erred in applying


the clearly erroneous standard to the Board's determination and


argues:


           "I. The statutory disqualification of an
           individual from receiving unemployment
           benefits if `unemployment results from a
           stoppage of work . . . that exists because of
           a labor dispute at the premises where the
           individual last was employed' requires only a
           substantial curtailment of operations of the


                                  - 4 -

          employer at the [specific workplace] where
          the individual applicant for unemployment was
          last employed and not of overall operations
          of the employer at all locations, and


                                  . . .


          II. Even assuming that a curtailment of the
          overall operations of an employer is legally
          required for the statutory disqualification
          to apply, the lower court erred in upholding
          a determination by the Board of Appeals that
          there was not a substantial curtailment of
          Giant's overall operations as a result of the
          strike in question."


                       STANDARD OF REVIEW

          Recently, in Consumer Protection Division v. Luskin's,


Inc., 120 Md. App. 1, 22, cert. granted, 350 Md. 280 (1998), we


reiterated:


               Our role in reviewing the decision of an
          administrative agency "is precisely the same
          as that of the circuit court." . . . We,
          therefore, do not evaluate the findings of
          fact and conclusions of law made by the
          circuit court.  We review the administrative
          decision itself, . . . and not the decision
          of the trial court. . . .


(Citations omitted.)  Thus, whether the circuit court applied the


wrong standard of review is of no consequence if our own review


satisfies us that the Board's decision was proper.


          In light of the expertise of administrative agencies,


"`decisions of administrative agencies are prima facie correct,'


. . . and `carry with them the presumption of validity' . . . ." 


Bulluck v. Pelham Wood Apartments, 283 Md. 505, 513


(1978)(citations omitted).  A reviewing court "may substitute its


                              - 5 -

own judgment for that of the agency when resolving questions of


law."  Luskin's, 120 Md. App. at 22-23.  See also Ramsay,


Scarlett & Co., Inc. v. Comptroller of the Treasury, 302 Md. 825,


837 (1985).  When the question is one of fact, however, judicial


review


          is narrow in scope and requires the exercise
          of restrained and disciplined judicial
          judgment. . . . Where the agency's findings
          of fact are supported by substantial
          evidence, in the form either of direct proof
          or permissible inference, in the record
          before the agency, an appellate court may not
          substitute its judgment, even on the question
          of the appropriate inference to be drawn from
          the evidence, for that of the agency. . . .
          Thus, if reasoning minds could reasonably
          reach the conclusion reached by the agency
          from the facts in the record, then it is
          based upon substantial evidence, and the
          court has no power to reject that conclusion.
          . . .


Liberty Nursing Center, Inc. v. Dep't of Health and Mental


Hygiene, 330 Md. 433, 442-43 (1993).  The reviewing court also


applies the substantial evidence test "when the only question is


whether the [administrative agency], having a correct


understanding of the law, properly applied the law to the facts." 


Supervisor of Assessments of Montgomery County v. Asbury


Methodist Home, Inc., 313 Md. 614, 627 (1988).


                                 - 6 -

                               DISCUSSION

                                   I

                    Scope of Stoppage of Work

          Section 8-1004 (a) of the Labor and Employment Article


provides in pertinent part:


               (1) an individual who otherwise is
          eligible to receive benefits is disqualified
          from receiving benefits for each week for
          which the Secretary finds that unemployment
          results from a stoppage of work, other than a
          lockout, that exists because of a labor
          dispute at the premises[ ] where the
                                        1

          individual last was employed; and


               (2) if separate branches of work that
          usually are conducted as separate businesses
          in separate premises are conducted in
          separate departments on the same premises,
          each department shall be considered a
          separate premises for the purpose of this
          subsection.


Md. Lab. and Empl. Code Ann. § 8-1004(a) (1991 Repl. Vol.).


          Giant contends that the phrase "at the premises 





     1Md. Ann. Code art. 95A, § 6(e) (1985 Repl. Vol.), the
predecessor to § 8-1004(a)(1), provided that an individual was
ineligible for benefits if his unemployment was "due to a stoppage
of work . . . which exists because of a labor dispute at the
factory, establishment, or other premises at which he is or was
last employed . . . ."  (Emphasis added.)  By 1991 Laws of
Maryland, Chapter 8, § 2, the Legislature revised, restated, and
recodified article 95A and other laws, creating the Labor and
Employment Article.  Section 6(e) of Article 95A became
§ 8-1004(a), and the words factory and establishment were deleted,
apparently as surplusage.  As stated in the revisor's note, the new
language was "derived without substantive change from former Art.
95A, § 6(e) . . . ."  Thus, the word "premises" in the current
statute implicitly encompasses a factory or establishment.


                              - 7 -

where the individual last was employed" in § 8-1004(a)(1)


modifies not only "labor dispute" but also "stoppage of work." 


Thus, Giant reads § 8-1004(a)(1) to state that an individual 


is ineligible for benefits if there was a "stoppage of work" 


at the "premises" where he was last employed.  It further


interprets "premises" to mean the specific workplace of the


individual within the employer's enterprise.  Giant concludes


that § 8-1004 disallows benefits if there was a stoppage of 


work at the individual's specific workplace, even if the


employer's business as a whole was not significantly 


affected.  Giant points out that, in determining that Giant


experienced no stoppage of work, the Board looked to Giant's


operations as a whole and not to the specific workplaces 


of the workers who filed claims for unemployment benefits.  


Giant argues that had the Board looked to the specific 


workplaces of the claimants -- the warehouse/distribution 


centers and manufacturing plants  -- it would have necessarily
                                2



determined that stoppages of work had occurred at those


workplaces and that the workers were ineligible for benefits.


          Preliminarily, there is some question as to whether


Giant's argument is properly before this Court.  The appellees


contend that Giant failed to argue to the Board of Appeals that



     2Giant posits that the workplaces of the truck drivers were
the warehouse/distribution centers.  That issue was not decided
below since the Board determined that there was no stoppage of
work.


                              - 8 -

the phrase "at the premises where the individual last was


employed" modifies "stoppage of work," or that the Board should


consider only the specific workplaces of the claimants in


determining if there was a stoppage of work.  The appellees point


out that, in a post-hearing memorandum, Giant urged the Board to


"look[] to [its] entire operation to determine whether any of its


major functions were substantially curtailed by the labor


dispute."  From this, the appellees conclude that Giant's


argument has been waived.  See generally Md. Rule 8-131(a). 


Giant counters that it repeatedly urged the Board to consider


what happened at the manufacturing plants and the


warehouse/distribution centers.  It contends that the quoted


portion of the post-hearing memorandum was designed to direct the


Board's attention to those workplaces and not to convince the


Board to look to its overall operations rather than the specific


workplaces.  Assuming without deciding that Giant's


characterization of its argument before the Board is the more


accurate one and that the argument is preserved, we are satisfied


that the Board properly construed § 8-1004(a)(1) and properly 


considered Giant's operations as a whole in deciding that there


was no stoppage of work.


          As the Court of Appeals has made clear, "`[t]he


cardinal rule of statutory construction is to ascertain and


effectuate the actual intent of the [l]egislature.'"  Hyle v.


Motor Vehicle Admin., 348 Md. 143, 148 (1997) (citation omitted). 


                              - 9 -

"To determine the legislature's intent, we must look `"`first to


the words of the statute, read in light of the full context in


which they appear, and in light of external manifestations of


intent or general purpose available through other evidence.'"'"


Id. (citations omitted).  "In interpreting a statute, `we


construe the statute as a whole, interpreting each provision of


the statute in the context of the entire statutory scheme.'" Id.


at 149.  "`Punctuation may, when the meaning of the statute is


uncertain, be looked to in ascertaining the real meaning, or, if


the punctuation gives the statute a reasonable meaning apparently


in accord with the legislative intent, it may be used as an


additional argument for adopting the literal meaning of the words


of the statute thus punctuated."' Webb v. City of Baltimore, 179


Md. 407, 409-10 (1941) (citation omitted).


          The plain language of the statute convinces us that the


Legislature did not intend for the phrase "at the premises where


the individual last was employed" to modify "stoppage of work." 


We conclude that the phrase modified the words "labor dispute,"


which immediately preceded it.3  See Sullivan v. Dixon, 280 Md.



     3The Court of Appeals has defined the boundaries of an
"establishment" for purposes of determining whether a labor dispute
occurred at the establishment where the claimant was last employed.
In Tucker v. American Smelting & Refining Co., 189 Md. 250 (1947),
a strike at the appellee's Garfield, Utah copper smelting plant
dried up supplies to the appellee's Baltimore refinery, ultimately
leading to lay-offs in Baltimore.  The Court of Appeals was asked
to determine whether the Utah smelting plant and the Baltimore
refinery were the same establishment, such that the labor dispute
in Utah would disqualify the Baltimore workers from collecting


                              - 10 -

444, 451 (1977) (following "the generally recognized rule of


statutory construction that a qualifying clause ordinarily is


confined to the immediately preceding words or phrase --


particularly in the absence of a comma before the qualifying


clause . . .").  Section 8-1004(a)(1) was carefully crafted to


disqualify from receiving benefits only those individuals whose


unemployment resulted from a stoppage of work, where the stoppage


of work was caused by a labor dispute that occurred at the



unemployment benefits.  The Court concluded that the two operations
did not constitute one establishment.  In addition to pointing to
the great physical distance between the operations, the Court noted
"the absence of evidence that the Garfield and Baltimore plants,
because of `functional integrality,' `general unity,' or `physical
proximity,' constitute a single `establishment.'" Id. at 256.


          As Tucker exemplifies, questions regarding the boundaries
of factories, establishments, or other premises most often arise
when there is no dispute that there was a stoppage of work but
there is a dispute as to whether the stoppage was due to a labor
dispute at the claimant's workplace.  Numerous courts in other
jurisdictions with provisions similar to § 8-1004(a)(1) have
wrestled with such questions, and the results have been strikingly
inconsistent.  See, e.g., Liberty Trucking Co. v. Dep't of Indus.,
Labor and Human Relations, 204 N.W.2d 457, 461-63 (Wis. 1973);
Ahnne v. Dep't of Labor and Indus. Relations, 489 P.2d 1397, 1401
(Haw. 1971); Ford Motor Co. v. Burson, 470 S.W.2d 941, 944 (Tenn.
1971); In the Matter of Claim of Sierant, 301 N.Y.S.2d 604, 608
(N.Y. 1969); Weiss v. Klein Supermarkets, Inc., 108 N.W.2d 4, 7-9
(Minn. 1961); Koll v. Edgekvist Bakeries, Inc., 107 N.W.2d 373, 376
(Minn. 1961); Kroger v. Industrial Comm'n, 314 S.W.2d 250, 254-55
(Mo. 1958); Ford Motor Co. v. Director of Div. of Employment, 96
N.E.2d 859, 862 (Mass. 1951); Ford Motor Co. v. Unemployment
Compensation Commission, 63 S.E.2d 28, 32-33 (Va. 1951); Ford Motor
Co. v. Abercrombie, 62 S.E.2d 209, 214-15 (Ga. 1950); Nordling v.
Ford Motor Co., 42 N.W.2d 576, 581-88 (Minn. 1950); Spielman v.
Indus. Comm'n, 295 N.W. 1, 3-5 (Wis. 1940); In the Matter of Claim
of DiLella, 368 N.Y.S.2d 300, 301-02 (N.Y. App. Div. 1975); Graham
v. Fred Sanders Co., 161 N.W.2d 601, 604-07 (Mich. Ct. App. 1968);
Basso v. News Syndicate Co., 216 A.2d 597, 600-05 (N.J. Super. Ct.
1966).


                              - 11 -

premises where the individuals were last employed.  Section


8-1004(b) provides a means for those individuals to show that


even though the labor dispute occurred at the premises where they


were last employed, they were not involved in the dispute and are


therefore eligible for benefits.  As implicitly made clear by


§ 8-1004(a)(2), § 8-1004(a)(1) does not disqualify individuals


whose unemployment resulted from a stoppage of work due to a


labor dispute that occurred at premises other than those at which


they were last employed.  Giant's reading of the statute to


disqualify individuals whose unemployment resulted from a


stoppage of work at the premises where they were last employed,


due to a labor dispute at those same premises, would leave in


limbo the eligibility for benefits of those individuals whose


unemployment is the result of a stoppage of work due to a labor


dispute at some other premises.  Our reading of the statute is


consistent with "the remedial nature of unemployment


compensation, from which flow the principles that such laws


should be read liberally in favor of eligibility . . . ."  


Sinai Hosp. v. Dep't of Employment and Training, 309 Md. 28, 40


(1987).


           We are convinced, moreover, that the Board properly


considered Giant's operations as a whole in determining that


there was no stoppage of work.  In Unemployment Benefits and the


"Labor Dispute" Disqualification, 17 U. Chi. L. Rev. 294, 311


(1949-50), commentator Milton I. Shadur addressed the


                                - 12 -

"troublesome" question of "whether benefits are payable during


disputes which cause a substantial production drop in one


department, though not in the entire plant."  Referring


specifically to statutes such as § 8-1004(a), Shadur wrote that a


majority of the states'


          "stoppage of work" statutes provide that if
          "separate branches of work which are commonly
          conducted as separate businesses in separate
          premises are conducted in separate
          departments of the same premises, each such
          department shall, for the purpose of this
          subsection, be deemed to be a separate
          factory, establishment, or other premises." 
          The implication is that departments which are
          not "commonly conducted as separate
          businesses in separate premises" do not
          possess independent status for the purpose of
          determining disqualification.  The test
          should thus be whether the stoppage was
          substantial in relation to the entire
          establishment's production, not merely to
          that of the department in which the dispute
          occurred.  This approach would be harmonious
          with the view that benefits should depend in
          part upon the likelihood of success of the
          employee's strike.


17 U. Chi. L. Rev. at 311-12 (emphasis in original).  


See generally Willard A. Lewis, The "Stoppage of Work" 


Concept in Labor Dispute Disqualification Jurisprudence, 


45 J. Urban L. 319, 334-35 (1967) (explaining that where


different branches of work are conducted as separate businesses


the measurement of stoppage of work is confined to the separate


branch alone).


          The Board of Appeals implicitly concluded that Giant's


manufacturing plants and warehouse/distribution centers are not


                             - 13 -

"conducted as separate businesses in separate premises."


§ 8-1004(a)(2).  We perceive no error.  Giant candidly describes


itself as "a vertically-integrated grocery operation."  There is


no indication that, at the relevant time, Giant's manufac-


turing plants or warehouse/distribution centers supplied any


entity other than Giant.  Giant does not contend that its


manufacturing plants or warehouse/distribution centers were


operated as separate businesses, and directs us to no evidence


before the Board that would indicate as much.  Compare 


Walgreen Co v. Murphy, 53 N.E.2d 390 (Ill. 1944) (drug 


company's warehouse, which supplied company's chain stores as


well as various other entities, was separate establishment 


such that court had only to look to whether there was stoppage 


of work at warehouse).


          Both appellants and appellees direct us to Employment


Sec. Admin. v. Browning-Ferris, Inc., 292 Md. 515, 517 (1982)


("BFI").  In that case, the Court of Appeals was asked to


determine whether the Board of Appeals properly determined that


claimants who had participated in a strike against their employer


were eligible to receive unemployment benefits on the ground that


there had been no stoppage of work as a result of the strike. 


The Court adopted the view held by the majority of states as to


their own unemployment insurance laws,  that the phrase "stoppage


of work" in the Maryland Unemployment Insurance Law refers to the


"curtailment of the employer's operations" and not to cessation


                               - 14 -

of the worker's labor.  Id. at 528.  The Court was not called


upon to address and did not address whether, for an employee to


be ineligible for unemployment benefits, the contemplated


stoppage of work must curtail the employer's operations as a


whole or must curtail only the operations at the employee's


specific workplace.  Indeed, there was no discussion as to


whether there was more than one workplace in Browning-Ferris. 


The Court merely suggested that the curtailment of the employer's


operations must be "substantial."  Id. at 528.  It recognized


"the difficulty of applying a fixed percentage rule to define


`substantial,'" id. at 529, and observed:


               "Since the mid-fifties, there has been a
          new emphasis placed upon the term
          `operations.'  As production increasingly
          represents less than totality of the
          employing unit's performance, decreases in
          business revenue, services rendered,
          marketing, research, and maintenance,
          transportation, and construction activities
          have come to the fore as indicia of
          substantialness."


                              - 15 -

Id. at 529-30 (quoting Lewis, 45 J. Urban L. at 322).   The Court
                                                        4



looked to the quoted criteria in determining that the Board


properly concluded that Browning-Ferris had not experienced a


work stoppage.  See 292 Md. at 530.


          In determining that a work stoppage occurs when there


is a substantial curtailment of the employer's operations, the


BFI Court relied on a number of decisions from other


jurisdictions with statutes similar to our own.  See 292 Md. at


528-29, n.13.  Three, in particular, are significant.  In


Continental Oil Co. v. Bd. of Labor Appeals, 582 P.2d 1236 (Mont.


1978), workers at an oil refinery were awarded unemployment


benefits for a period during which they were on strike on the


ground that there was no stoppage of work.  The employer


appealed, arguing that, although production levels remained


normal, there were stoppages in areas such as "training,


planning, budgeting, etc."  Id. at 1244.  The Supreme Court of




     4Lewis explains the significance of the use of the word
"substantial" to modify curtailment or stoppage of work.  He
observes that most states, like Maryland, modeled their
unemployment compensation statutes after the Social Security Draft
Bill, which in turn was modeled after the British Unemployment
Insurance Acts.  See 45 J. Urban L. at 322.  See also BFI, 292 Md.
at 521-22.  While British courts have determined that a stoppage of
work must be "appreciable" before a striking worker will be
ineligible for benefits, a majority of the state courts have held
that the stoppage must be "substantial."  According to Lewis, the
appreciable standard "was more concerned with computing the numbers
of vacancies occasioned by the labor dispute; the [substantial
standard] introduced the variety of factors which bear upon the
overall operation of the employer's business."  45 J. Urban L. at
327. 


                             - 16 -

Montana rejected the argument, explaining: "We do not accept


. . . the proposition that whenever a labor dispute forces a


change in an employer's method of operation or causes a


curtailment of some activities within the plant, there per se


exists a stoppage of work."  Id. at 1245.


          In Meadow-Gold Dairies - Hawaii, Ltd. v. Wiig, 437 P.2d


317 (Haw. 1968), the appeals of two dairies that were struck by


union workers were consolidated.  The Supreme Court of Hawaii


affirmed referee determinations that the dairies experienced no


stoppages of work, even though production at one dairy declined


18.65% and production at the other declined 17.66%, and both


dairies were forced to cease all door-to-door deliveries. 


Similar to the Court in Continental Oil, the Court commented: "We


do not accept the proposition that whenever a labor dispute


forces a significant change in an employer's method of operation,


or necessitates a part of the production process to leave the


plant, there exists a `stoppage of work.'" 437 P.2d at 320-21.


          The Supreme Court of West Virginia upheld a


determination that there was no stoppage of work at a gas utility


in Cumberland and Allegany Gas Co. v. Hatcher, 130 S.E.2d 115 (W.


Va. 1963), overruled on other grounds, Lee-Norse Co. v. Rutledge,


291 S.E.2d 477 (W. Va. 1982).  In that case, the employer was


able to supply gas to all of its customers and to generate bills,


but was unable to handle routine service orders, read domestic


                             - 17 -

meters, install new service lines, or perform maintenance work. 


The Court explained:


           . . . In some situations, a substantial
          curtailment of work in a single category or
          department of the employer's operations might
          be of such a vital nature as to result in a
          substantial curtailment of the employer's
          activities if all categories or departments
          were of an interdependent nature; while,
          conceivably, in another and different
          situation, a complete cessation of work in a
          single category or department of some
          incidental or minor nature might produce no
          appreciable curtailment of the overall
          operations of the employer.


Id. at 121.


          In short, the cases on which the Court of Appeals


relied in BFI when it adopted the "substantial curtailment" test


for determining when there has been a stoppage of work looked to


the overall operations of the employer and not to the operations


of any specific workplace.  As the BFI Court indicated, the test


itself involves a review of the totality of the circumstances of


the employer's operations.  See 292 Md. at 529.  See generally


Thomas J. Goger, Annotation, Construction of Phrase "Stoppage of


Work" in Statutory Provision Denying Unemployment Compensation


Benefits During Stoppage Resulting From Labor Dispute, 61


A.L.R.3d 693 (1975).


          In determining that Giant did not experience a


substantial stoppage of work and that the striking workers were


therefore eligible to receive unemployment benefits, the Board of


Appeals did not attempt -- and was not asked -- expressly to


                             - 18 -

define the premises that it was considering.  The Board


implicitly looked to the operations as a whole, a course of


action it was entitled to take absent evidence that Giant's


manufacturing plants and warehouse/distribution centers were


operated as separate businesses.  See, e.g., Asher v. C&P


Telephone Co. of Md., Decision No. 881-BH-84 (Nov. 8, 1984);


Barnes v. AT&T, Decision No. 891-BH-84 (Nov. 14, 1984).  See also


Tracey v. American Totalisator Co., Benefit Determination No. 409


(Oct. 21, 1986).


                               II

        Substantial Curtailment of Operations as a Whole

          In the alternative, Giant argues, in essence, that even


if the Board properly considered its operations as a whole, the


Board erred in determining that the operations were not


substantially curtailed.  Giant posits that the Board gave


insufficient weight to, inter alia, the shutdowns of the


manufacturing plants and warehouse/distribution centers, lost


manufacturing profits, and increased costs due to the strike.  
                                                                 5



As we have indicated, in reviewing the Board's decision on a


question of fact or a mixed question of fact and law, a reviewing


court must affirm the Board "if reasoning minds could reasonably





     5For instance, although Giant presented evidence that it
incurred approximately $2.2 million in increased transportation
costs and lost $500,000 worth of perishable products, the Board
made no mention of the evidence in its determination.


                             - 19 -

reach the conclusion reached by the agency from the facts in the


record." Liberty Nursing Center, 330 Md. at 443.


          As the Court of Appeals held in BFI, 292 Md. at 529-30,


a flexible balancing test is to be applied in determining if


there was a stoppage of work.  In addition to declines in


production, "decreases in business revenue, services rendered,


marketing, research, and maintenance, transportation, and


construction activities," as well as any other relevant


considerations, must be weighed.  Id.  In accordance with BFI,


the Board expressly considered that Giant had: closed its


manufacturing plants and warehouse/distribution centers;


experienced a decrease in aggregate sales of food and drugs of


approximately 14.82%; experienced a drop in customer count of


from 6% to 10% from the year before; and incurred increased costs


of approximately $3.9 million to replace goods it ordinarily


manufactured.  The Board acknowledged that Giant had presented


evidence that it lost approximately $4 million in manufacturing


profit, but explained that it did not find the loss to be a


significant factor in determining whether a stoppage of work had


occurred, apparently in light of the related figures for overall


sales losses.  The Board pointed out that Giant's stores had


remained open and that Giant had managed to keep the stores


stocked by using outside vendors.  It noted that just ten days


before the strike ended Giant's spokesperson had told the press


that, although sales were "slightly down," the "recent mild


                             - 20 -

weather and the typical post-holiday dip in sales" could be


factors.  On the record before us, we cannot conclude that


reasoning minds could not reasonably have reached the decision


reached by the Board.


                                   JUDGMENT AFFIRMED; APPELLANT
                                   TO PAY THE COSTS.