Can the Burns Successorship Doctrine Survive the GVS Properties Decision?

In February 2012, GVS Properties, LLC purchased several real estate properties in New York City from Broadway Portfolio, LLC. (“Broadway”). Broadway had subcontracted the maintenance of the properties to Vantage Building Services, LLC. (“Vantage”). The employees of Vantage were represented by the International Association of Aerospace Workers, District Lodge 15, Local Lodge 447 (“union”). At the time of the sale of the properties, the Union and Vantage were parties to a collective bargaining agreement covering the terms and conditions of the maintenance workers.