# NLRB Division of Advice Memorandum, Case No. 18-CA-300972 (Trustees of Grinnell College): Trustees of Grinnell College (18-CA-300972)

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_18-CA-300972

## Section

- **Citation:** NLRB Division of Advice Memorandum, Case No. 18-CA-300972 (Trustees of Grinnell College)
- **Heading:** Trustees of Grinnell College (18-CA-300972)
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** NLRB Division of Advice Memoranda (rolling 10-year window) / Trustees of Grinnell College (18-CA-300972)

## Text

United States Government
National Labor Relations Board
OFFICE OF THE GENERAL COUNSEL
Advice Memorandum
S.A.M.
DATE:
May 25, 2023
TO:
Jennifer Hadsall, Regional Director
Region 18
FROM:
Richard A. Bock, Associate General Counsel
Division of Advice
SUBJECT: Trustees of Grinnell College
Case 18-CA-300972
133-0100-0000-0000
530-6067-6067-6000
530-6067-6067-5200
530-6067-6067-6033

This case was submitted for advice as to whether the Employer violated the Act
when it refused to provide names, contact information, and job titles for unit
employees as requested by the Union. The Employer asserted that the requested
information included confidential education records and providing it to the Union
without student-employees’ consent would run afoul of the Employer’s duties under
the Family Educational Rights and Privacy Act of 1974 (“FERPA”). We first conclude
that the Employer failed to show that the records requested are education records as
defined by FERPA and therefore failed to establish it had a legitimate and substantial
confidentiality interest in the requested information. Accordingly, the Employer
violated Section 8(a)(5) by failing to provide the Union with the information. Second,
even assuming FERPA applies to the requested information, we conclude that
issuance of complaint, absent settlement, is still appropriate. Although the Employer
satisfied its initial obligation to offer an accommodation on how to provide the
information while complying with FERPA, and the parties met and bargained over
accommodation proposals, the parties could not reach agreement to resolve the
dispute. Thus, the Board must balance the parties’ interests and strike an
appropriate accommodation in light of the parties’ proposals
Although the Employer
satisfied its initial obligation to offer an accommodation on how to provide the
information while complying with FERPA, and the parties met and bargained over
accommodation proposals, the parties could not reach agreement to resolve the
dispute. Thus, the Board must balance the parties’ interests and strike an
appropriate accommodation in light of the parties’ proposals. In litigating this case,
the Region should take the position that the proper balancing and accommodation
here is for the Employer to affirmatively seek releases from student-employees
actually covered by FERPA and, for those who refuse or fail to sign a release, provide
the Union with de-identified information.

FACTS

Grinnell College (“Employer”) is a private not-for-profit college in Grinnell, Iowa
that educates undergraduate students. The Union of Grinnell Student Dining
Workers (“Union”) was initially formed in 2016 to represent the Employer’s dining
hall student-employees. After the Union was elected and certified, the parties entered

Case 18-CA-300972

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into multiple successive collective-bargaining agreements. The most recent collective-
bargaining agreement is effective from July 1, 2021 to June 30, 2023.

In early 2022,1 the Union sought to represent all of the Employer’s student-
employees. The Employer and Union entered into a neutrality agreement in March,
and in May the Union won the election and was certified as the representative of
virtually all student-employees. Soon after, the Union sought to accrete into the unit
the Employer’s Community Advisors, who had been explicitly excluded from the
certified unit. The Employer voluntarily recognized the Union as the representative of
those additional student-employees upon a showing of majority support via card
check
won the election and was certified as the representative of
virtually all student-employees. Soon after, the Union sought to accrete into the unit
the Employer’s Community Advisors, who had been explicitly excluded from the
certified unit. The Employer voluntarily recognized the Union as the representative of
those additional student-employees upon a showing of majority support via card
check.

On June 28, in preparation for bargaining for a successor contract, the Union
emailed the Employer an information request seeking, among other items, names,
contact information, and bargaining unit job titles for all bargaining unit student-
employees as well as race, ethnicity, and gender for each unit member. On July 6, the
Employer informed the Union that information on individual student-employees
implicated FERPA and the Employer would need each student-employee to sign a
release before the Employer could provide such unit data.2

FERPA protects the privacy of student education records; colleges or universities
that violate FERPA are subject to the loss of federal funding.3 FERPA provides that
postsecondary schools must obtain a student’s written, prior consent when disclosing
“personally identifiable information” from education records, unless an exception
applies.4 The exceptions include, among others, records that are considered student
“directory information.”5

On July 15 and 18, the Union communicated its view that FERPA releases were
not necessary to disclose unit membership and contact information because the
Employer provided the Union with similar information in the past without obtaining

1 All dates hereinafter are in 2022, unless otherwise stated.
2 The remaining information requested was either provided or the parties agreed was
no longer necessary.
3 20 U.S.C. § 1232g(a), (b); 34 C.F.R. §§ 99.1–5.
4 20 U.S.C. § 1232g(b)(1), (d); 34 C.F.R. § 99.30.
5 20 U.S.C. § 1232g(a)(5)(B), (b)(1); 34 C.F.R. § 99.37(a).
ilar information in the past without obtaining

1 All dates hereinafter are in 2022, unless otherwise stated.
2 The remaining information requested was either provided or the parties agreed was
no longer necessary.
3 20 U.S.C. § 1232g(a), (b); 34 C.F.R. §§ 99.1–5.
4 20 U.S.C. § 1232g(b)(1), (d); 34 C.F.R. § 99.30.
5 20 U.S.C. § 1232g(a)(5)(B), (b)(1); 34 C.F.R. § 99.37(a).

Case 18-CA-300972

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releases,6 it constituted directory information, and employment information is not an
education record. As to the request for race, ethnicity, and gender information, the
Union consented to the Employer providing aggregate, de-identified data instead.

In its reply on July 19, the Employer asserted that the intersection of the Act and
FERPA was a developing area of law and that it had to balance its duties under the
Act with its duty to keep students’ personal information confidential under FERPA.
The Employer explained that when directory information is combined, directly or
indirectly, with private information, a FERPA release is required. In other words,
providing directory information, such as names and contact information, for a subset
of students—e.g. only those employed by the college—would be prohibited absent
their consent. The Employer offered to contact students to obtain such releases. It
also indicated that it was exploring the possibility of a blanket release authorizing
disclosure of employment data to the Union to avoid the need for releases for each
information request. The Employer offered to meet and the Union requested that the
parties do so.

On August 1, the parties met to discuss the issues concerning the information
request and FERPA
o obtain such releases. It
also indicated that it was exploring the possibility of a blanket release authorizing
disclosure of employment data to the Union to avoid the need for releases for each
information request. The Employer offered to meet and the Union requested that the
parties do so.

On August 1, the parties met to discuss the issues concerning the information
request and FERPA. The Union pressed the Employer as to why it had changed its
position on needing individual releases to furnish information, whether the requested
records were actually education records, and why such information was not covered
by the directory information exemption, especially since it had been provided in the
past. The Employer reiterated that this was an evolving area of law, explained that
its understanding of the law had changed, and that these were education records that
required a release. The Employer also distinguished between voter lists provided
during the unionization process and unit information relevant to the collective-
bargaining process.7 The Union inquired about the downside risk of furnishing the
information without releases and pointed out that some employment information was
already effectively public since the Employer published lists of Community Advisors
and other positions to the student body. The Union also noted that it was aware of
another college that agreed to provide similar information to the corresponding union
without a FERPA release. The Union suggested that the parties employ an opt-out
process—i.e., students would be notified of the expected release of information and
could object to the disclosure of their individual information—and asserted that the

6 The Employer previously provided similar information during the initial election
process, in connection with the neutrality agreement, and for the dining hall student-
employees from 2016 onward
oy an opt-out
process—i.e., students would be notified of the expected release of information and
could object to the disclosure of their individual information—and asserted that the

6 The Employer previously provided similar information during the initial election
process, in connection with the neutrality agreement, and for the dining hall student-
employees from 2016 onward.
7 At some point during the meeting, the parties discussed the fact that during
negotiations for the neutrality agreement, the Employer had determined that voter
information constituted directory information.

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collective-bargaining agreement contemplated such a process.8 The Employer
responded that it would need to speak with legal counsel about the opt-out proposal.
The Employer offered to give the Union a roster of students and the Union could
reach out to students directly to obtain FERPA releases. The Union told the Employer
that it would file an unfair labor practice charge with the Board if the Employer did
not immediately provide the requested information without FERPA releases. It
further stated that the Employer’s insistence on releases meant the information
would not be provided in a timely manner, which would impede the Union’s ability to
negotiate. The parties were unable to reach an accommodation during the meeting.
That evening, the Union followed up with the Employer by email asking for a
response on the one-time opt-out suggestion.

On August 3, the Employer notified the Union that it would not be able to
provide the requested information without a FERPA release from each student. It
explained that an opt-out process would not meet FERPA standards. It offered to
provide generic pay and position data and to use its electronic communications system
to request release authorizations from student-employees
ut suggestion.

On August 3, the Employer notified the Union that it would not be able to
provide the requested information without a FERPA release from each student. It
explained that an opt-out process would not meet FERPA standards. It offered to
provide generic pay and position data and to use its electronic communications system
to request release authorizations from student-employees. The Union responded on
August 4, complaining that the Employer was deviating from its prior practice and
suggesting the Employer designate certain employment data “directory information.”
According to the Union, that process contemplates an opt-out period and the Union
proposed giving student-employees a week to opt out. The Union informed the
Employer if it did not guarantee within 48 hours that the information would be
provided either with no release or via an opt-out process, the Union would file an
unfair labor practice charge with the Board.

On August 6, the Employer responded and listed four options for the Union to
choose from on how to proceed: (1) obtain FERPA releases from students, which the
Employer again offered to send out to student-employees; (2) provide generic pay and
position data not linked to any personally identifiable information as well as a list of
enrolled students; (3) consider altering “directory information” to include place and
position of employment (but not any other employment-related information), which
the Employer cautioned would first require considerable deliberation with key
stakeholders in the campus community; or (4) file an unfair labor practice charge.

On August 8, the Union replied that none of those options satisfied the
Employer’s obligation to provide information under the Act
include place and
position of employment (but not any other employment-related information), which
the Employer cautioned would first require considerable deliberation with key
stakeholders in the campus community; or (4) file an unfair labor practice charge.

On August 8, the Union replied that none of those options satisfied the
Employer’s obligation to provide information under the Act. While the Union
expressed appreciation for the Employer’s willingness to explore designating certain
employment information as directory information, it disagreed with the need for

8 Section 3.1 of the collective-bargaining agreement states: “The parties recognize that
to fulfill its obligation to represent employees under this Agreement, the Union
should have access to the names and contact information of employees covered by this
Agreement. The parties recognize and agree that Employee students may choose to
keep their contact information confidential.”

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stakeholder deliberations, which would cause further delay. Accordingly, the Union
proceeded with filing the instant charge alleging a failure to furnish names, contact
information, and job titles for the bargaining unit. The Union subsequently requested,
and the Employer provided, estimates as to how long each of the above options would
take. The parties have yet to reach agreement on how to proceed.

ACTION

We first conclude that the Region should issue complaint, absent settlement,
alleging the Employer violated Section 8(a)(5) by refusing to furnish the requested
unit information because the Employer has failed to establish that the information
was subject to FERPA. Second, even assuming it could substantiate its confidentiality
interest, complaint should issue because the parties could not reach an
accommodation and the information at issue has not been provided
ment,
alleging the Employer violated Section 8(a)(5) by refusing to furnish the requested
unit information because the Employer has failed to establish that the information
was subject to FERPA. Second, even assuming it could substantiate its confidentiality
interest, complaint should issue because the parties could not reach an
accommodation and the information at issue has not been provided. The Region
should then submit to the Board that the appropriate balance and accommodation in
the instant case is for the Employer to affirmatively seek FERPA releases from any
student-employees who are actually covered by FERPA, turn over the information to
the Union for those who signed, and, because some may fail or refuse to sign a
release, provide the Union with their respective de-identified information.

A. Legal Principles

A collective-bargaining representative is entitled to information relevant and
necessary to carry out its statutory duties and responsibilities, including bargaining
for a successor collective-bargaining agreement.9 When an employer asserts that
information requested by a union is confidential, the Board balances the union’s need
for the relevant information against any legitimate and substantial confidentiality
interests asserted by the employer.10 When the assertion stems from a state or federal
law, the Board will consider that in its assessment of whether a legitimate

9 See, e.g., Detroit Edison Co. v. NLRB, 440 U.S. 301, 303 (1979); NLRB v. Acme
Indus. Co., 385 U.S. 432, 435–36 (1967); NLRB v. Truitt Mfg. Co., 351 U.S. 149, 151–
53 (1956).
10 See Mobil Oil Corp., 303 NLRB 780, 780–81 (1991) (employer’s confidentiality
interest in drug informant’s identity not so great as to excuse failure to disclose any
information; employer ordered to produce summary of informant’s report); Minnesota
Mining & Mfg
U.S. 301, 303 (1979); NLRB v. Acme
Indus. Co., 385 U.S. 432, 435–36 (1967); NLRB v. Truitt Mfg. Co., 351 U.S. 149, 151–
53 (1956).
10 See Mobil Oil Corp., 303 NLRB 780, 780–81 (1991) (employer’s confidentiality
interest in drug informant’s identity not so great as to excuse failure to disclose any
information; employer ordered to produce summary of informant’s report); Minnesota
Mining & Mfg. Co., 261 NLRB 27, 30–31 (1982) (employer failed to substantiate
confidentiality interest in substances used and produced at plant based on trade
secrets as to vast majority of substances; ordering bargaining over protective
safeguards as to substances that, if known to a competitor, could put employer at
competitive disadvantage), enforced sub nom. Oil, Chem. & Atomic Workers Local 6-
418 v. NLRB, 711 F.2d 348 (D.C. Cir. 1983).

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confidentiality interest exists.11 The employer has the burden to establish that it has
such a confidentiality interest and that this interest outweighs the union’s need for
the information.12 If established, the employer may not simply refuse to furnish the
requested information but must seek an accommodation with the union that will
effectuate the union’s interest in obtaining the information.13 Thus, it is the
employer’s duty to offer the union a reasonable accommodation.14 If the union is not
satisfied with the employer’s proffered accommodation, it is required to respond and
explain why the employer’s offer is insufficient but it need not propose a precise
alternative.15 Where the parties are unable to reach an accommodation, despite good
faith bargaining, the Board will balance the parties’ respective interests and strike an
accommodation “in light of proposals made during bargaining.”16

11 See Borgess Medical Center, 342 NLRB 1105, 1105 (2004) (recognizing state law
that deemed medical incident reports sought by union confidential); GTE California,
Inc., 324 NLRB 424, 425 n.2, 426–27 & n.5 (1997) (taking into account
g, the Board will balance the parties’ respective interests and strike an
accommodation “in light of proposals made during bargaining.”16

11 See Borgess Medical Center, 342 NLRB 1105, 1105 (2004) (recognizing state law
that deemed medical incident reports sought by union confidential); GTE California,
Inc., 324 NLRB 424, 425 n.2, 426–27 & n.5 (1997) (taking into account that customer
contact information sought by union was not subject to disclosure except in limited
circumstances under state law).
12 A-1 Door & Building Solutions, 356 NLRB 499, 500–01 (2011).
13 Id.; Metropolitan Edison Co., 330 NLRB 107, 107–08 (1999) (flat rejection of
request for informant names constituted failure to bargain to accommodate union’s
interest); GTE California, 324 NLRB at 426–27 (employer acted lawfully by offering
accommodation that parties bargained over and union ultimately accepted, namely,
connecting union with complaining customer by telephone rather than providing
customer’s unlisted information).
14 Borgess, 342 NLRB at 1106 (employer’s proposed accommodation—department
head’s general testimony about prior medical incidents—not sufficient to provide
specific disparate treatment evidence for union to prepare for grievance arbitration).
15 Id.; Piedmont Gardens, 362 NLRB 1135, 1137 n.7 (2015), enforced sub nom. Am.
Baptist Homes of the W. v. NLRB, 858 F.3d 612 (D.C. Cir. 2017). See Allen Storage &
Moving Co., 342 NLRB 501, 503 (2004) (employer fulfilled bargaining obligation by
offering to open its books in lieu of producing business records revealing customer
names but union refused without discussion or explanation).
16 Metropolitan Edison, 330 NLRB at 109–10 (where employer failed to seek an
accommodation, Board ordered accommodation bargaining while recognizing that the
parties may return to the Board if unable to reach agreement).
led bargaining obligation by
offering to open its books in lieu of producing business records revealing customer
names but union refused without discussion or explanation).
16 Metropolitan Edison, 330 NLRB at 109–10 (where employer failed to seek an
accommodation, Board ordered accommodation bargaining while recognizing that the
parties may return to the Board if unable to reach agreement).

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B. The Employer Failed to Show its Confidentiality Interest in the
Requested Information Was Legitimate and Substantial

Under FERPA, postsecondary schools must obtain a student’s written, prior
consent when disclosing “personally identifiable information” contained in education
records unless an exception applies.17 Employment records are only subject to FERPA
as education records if the student-employee is “employed as a result of [their] status
as a student.”18

Here, although the Employer, as an educational institution, has a substantial
and legitimate confidentiality interest in education records subject to FERPA, the
Employer has failed to show that the particular student-employee records sought by
the Union meet the definition of education records under FERPA. We recognize where
FERPA confidentiality requirements are established, the Employer has a significant

17 20 U.S.C. § 1232g(b)(1); 34 C.F.R. § 99.30. Although the statute is written in terms
of parental consent, the permission required transfers to the student once they attend
a postsecondary institution. See 20 U.S.C. § 1232g(d).
18 34 C.F.R. § 99.3(b). The statute broadly defines education records as those
containing “information directly related to a student” that are maintained by an
educational institution. 20 U.S.C. § 1232g(a)(4). The corresponding regulation
contains the same broad definition, but states that the term “education records”:

does not include: . . .
(3)
institution. See 20 U.S.C. § 1232g(d).
18 34 C.F.R. § 99.3(b). The statute broadly defines education records as those
containing “information directly related to a student” that are maintained by an
educational institution. 20 U.S.C. § 1232g(a)(4). The corresponding regulation
contains the same broad definition, but states that the term “education records”:

does not include: . . .
(3)
(i) Records relating to an individual who is employed by an
educational agency or institution, that:
(A) Are made and maintained in the normal course of
business;
(B) Relate exclusively to the individual in that individual’s
capacity as an employee; and
(C) Are not available for use for any other purpose.
(ii) Records relating to an individual in attendance at the agency
or institution who is employed as a result of his or her status as a
student are education records and not excepted under paragraph
(b)(3)(i) of this definition.

34 C.F.R. § 99.3(b) (Emphasis added.). Although paragraph (3)(ii) above is preceded
by exclusionary language (“does not include”), the Department of Education has
treated the emphasized language above as dispositive in opinion letters to unions and
educational institutions—in other words, the administering agency interprets the
regulation to mean that FERPA protects employment records only if an individual’s
employment is contingent on their status as a student.

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stake in complying with the statute because it otherwise risks losing its federal
funding.19 But not all student employment records are covered by FERPA
cational institutions—in other words, the administering agency interprets the
regulation to mean that FERPA protects employment records only if an individual’s
employment is contingent on their status as a student.

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stake in complying with the statute because it otherwise risks losing its federal
funding.19 But not all student employment records are covered by FERPA. Indeed,
while a graduate student working for a university-employer as a teaching assistant or
a resident assistant working in student housing might fairly be assumed to be
employed contingent on being a student, the same cannot be said of a student-
employee working in the dining hall, such as those included in the unit at issue
here.20 Accordingly, the Employer had the burden to show that the employment of the
students covered by the request is contingent on them being enrolled at the college in
order for its invocation of FERPA to be effective and it failed to meet this burden. For
example, it has not provided job announcements describing that only enrolled
students may apply or employment contracts demonstrating that employment was
dependent on student status. Thus, the Employer unlawfully failed to furnish the unit
information requested by the Union because its confidentiality concerns are
unsubstantiated.

C. Even Assuming a Legitimate and Substantial Confidentiality Interest
Exists, Complaint Should Issue to Allow the Board to Balance the
Parties’ Interests

Assuming the Employer had shown the records were subject to FERPA, issuance
of complaint, absent settlement, is nonetheless warranted in this case. We recognize
that the Employer generally complied with the duties imposed on a party raising
confidentiality concerns in response to an information request
st
Exists, Complaint Should Issue to Allow the Board to Balance the
Parties’ Interests

Assuming the Employer had shown the records were subject to FERPA, issuance
of complaint, absent settlement, is nonetheless warranted in this case. We recognize
that the Employer generally complied with the duties imposed on a party raising
confidentiality concerns in response to an information request. It timely raised its
confidentiality interests with the Union and presented a reasonable accommodation
by offering to seek written releases from students so that it could provide the
requested information to the Union and still comply with its FERPA obligations.21
The parties also engaged in back-and-forth, good faith discussions to try to reach
agreement on a satisfactory accommodation. The parties met to discuss

19 See Borgess, 342 NLRB at 1105–06 (state law prohibiting disclosure of information
about a facility’s self-review documentation supported legitimacy of confidentiality
interest); GTE California, 324 NLRB at 426–27 (state law ensuring customer
confidentiality serves important public policy that Board cannot ignore even if it
would be preempted). See generally Novotel New York, 321 NLRB 624, 639 n.69 (1996)
(in enforcing Act, Board must be cognizant of obligation to consider other federal
statutes and the public policy behind their Congressional objectives).
20 It is unclear from the existing evidence whether Community Advisors serve a
function similar to a resident assistant.
21 See Detroit Edison, 440 U.S. at 317–20 (denying enforcement of Board order
requiring employer to unconditionally provide employee aptitude test scores where
employer had well founded confidentiality interest and was willing to disclose scores
upon receipt of written consents).
s unclear from the existing evidence whether Community Advisors serve a
function similar to a resident assistant.
21 See Detroit Edison, 440 U.S. at 317–20 (denying enforcement of Board order
requiring employer to unconditionally provide employee aptitude test scores where
employer had well founded confidentiality interest and was willing to disclose scores
upon receipt of written consents).

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accommodation options and continued the exchange of ideas over email. Ultimately,
however, the parties were not able to reach agreement and the requested information
has not yet been provided in any form. Thus, at this point, the Board needs to strike
an accommodation in light of the options discussed by the parties.

We note that this case is distinguishable from Allen Storage & Moving, where the
Board dismissed the information request allegation against the employer because the
employer there offered an accommodation but the union failed to accept it and did not
engage in any discussions or provide an explanation.22 Here, although the Union
failed to accept any of the Employer’s offers, it engaged in discussions about
alternative options for obtaining the information, conveyed the reasons for its
skepticism of the Employer’s FERPA-based concerns, and gave explanations as to why
the proffered accommodations were unsatisfactory. Indeed, the Union offered counter
proposals, which the Employer rejected, claiming they did not satisfy FERPA’s
disclosure requirements or would take significant time to implement.

Because the parties were unable to achieve an accommodation through
bargaining, issuing complaint alleging the Employer violated Section 8(a)(5) is
necessary to present the issue to the Board so that it may balance the parties’
interests and determine an appropriate accommodation in light of their proposals
during bargaining
osure requirements or would take significant time to implement.

Because the parties were unable to achieve an accommodation through
bargaining, issuing complaint alleging the Employer violated Section 8(a)(5) is
necessary to present the issue to the Board so that it may balance the parties’
interests and determine an appropriate accommodation in light of their proposals
during bargaining. In this case, the Region should urge the Board to order the
Employer—as to any student-employees’ records that the Employer has established
are subject to FERPA—to obtain individual FERPA releases from those student-
employees and provide the information for those who signed. Because some students
may fail or refuse to execute a release, the Employer should also provide the Union
with de-identified information about those bargaining unit employees. This approach
properly balances the Employer’s duties under the Act and FERPA while also
recognizing the Union’s legitimate need to receive the information and its stated
interest in doing so as expeditiously as possible.23

22 342 NLRB at 503.
23 The Region should note in its briefs to the ALJ and Board that such an order would
not preclude the parties from bargaining over classifying certain categories of
information as “directory information” to streamline the sharing of basic unit
information on an opt-out basis in the future. See 34 C.F.R. § 99.3 (defining directory
information as “information contained in an education record of a student that would
not generally be considered harmful or an invasion of privacy if disclosed” and
providing a non-exhaustive list of examples).

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- [NLRB Division of Advice Memorandum, Case No. 01-CB-241548 (IBEW Local 103 (Encore Boston Harbor)) IBEW Local 103 (Encore Boston Harbor) (01-CB-241548)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_01-CB-241548.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-040028 (Rogan Brothers Sanitation, Inc.) Rogan Brothers Sanitation, Inc. (02-CA-040028)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-040028.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-182019 (Epiq Document Review) Epiq Document Review (02-CA-182019)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-182019.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-183801 (The Trump Corp.) The Trump Corp. (02-CA-183801)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-183801.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-199415 (Trade Off, LLC) Trade Off, LLC (02-CA-199415)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-199415.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-204176 (Libra Services) Libra Services (02-CA-204176)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-204176.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-231984 (Nusr-Et Steakhouse) Nusr-Et Steakhouse (02-CA-231984)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-231984.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CA-262630 (Fox Television Stations) Fox Television Stations (02-CA-262630)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CA-262630.md)
- [NLRB Division of Advice Memorandum, Case No. 02-CB-184756 (Electrical Workers Local 3 (Time Warner Cable New York)) Electrical Workers Local 3 (Time Warner Cable New York) (02-CB-184756)](https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_02-CB-184756.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/NLRB_ADVICE_18-CA-300972. Check the current official text before relying on it. Not legal advice.