for the Study of Collective Bargaining in Higher Education and the Professions


February 2015
The National Center E-Note is an electronic newsletter providing news, updates and
analysis concerning events and issues of interest to our constituency groups.

Register Now for the National Center's 42nd Annual Conference on April 19-21, 2015 at the CUNY Graduate Center in New York City
The National Center's 42nd Annual Conference will take place on April 19-21, 2015 at the CUNY Graduate Center in New York City.  The theme of the conference will be Thinking about Tomorrow: Collective Bargaining and Labor Relations in Higher Education.  Early registration is highly recommended.

Click here for conference brochure. (Please note that hotel rooms are currently available only at the Affinia Shelburne hotel.)

Click here for conference schedule.

Click here for conference registration form.

Click here for credit card payment of conference fees.

Click here to register for conference workshops.

The conference will include panels and interactive workshops on: civility and academic freedom; the NLRB's recent Pacific Lutheran University decision; negotiating about tenure track faculty, contingent faculty and graduate assistants; first contracts at the University of Oregon, Georgetown University and Tufts University; the use of financial data; faculty salary schedules and pay equity; effective contract administration; sexual assaults on campus; and many other important topics. 
Locations, Events and Hotels for 42nd Annual Conference

Conference Locations and Events:


Sunday, April 19, 2015, CUNY Graduate Center: 365 5th Avenue, NY, NY, 10016 (reception, research panels and workshops)


Sunday, April 19, 2015, Heartland Brewery-Empire State Building: 350 5th Avenue, New York, NY 10118 (buffet dinner, open bar)


Monday-Tuesday, April 20-21, 2015, CUNY Graduate Center: 365 5th Avenue, NY, NY, 10016 (continental breakfast, panels, lunch and workshops)


Please note the new locations for the Sunday, April 19th events are the CUNY Graduate Center and the Heartland Brewery.


Conference Hotels:


Affinia Dumont: 150 East 34th Street, NY, NY, 10016

(note: the block at the Dumont is closed)


Affinia Shelburne: 303 Lexington Avenue, NY, NY, 10016


Room Rate: $289/night.    


Click here for hotel reservation information. (Note: new reservations are currently available only at the Affinia Shelburne hotel.)


Two Additional Commentaries on the NLRB's Pacific Lutheran Decision

The  decision by the National Labor Relations Board (NLRB) in Pacific Lutheran University was the subject of commentary in our January 2015 E-Note.  The decision will be an important topic of discussion and analysis at our annual conference in April.  In preparation for the conference, we have chosen to present two additional commentaries concerning the decision.   


The first commentary is by Joseph W. Ambash, Fisher & Phillips LLP who represents colleges and universities.  It was originally published in the New England Journal of Higher Education NEJHE, and it is reprinted with permission.  The second article is by Aaron Nisenson, Senior Counsel, American Association of University Professors, which was originally posted on the AAUP website.   


Both pieces underscore the significance of the Pacific Lutheran University decision and its impact on the future of faculty collective bargaining at private sector colleges and universities. 


Key NLRB Decision Opens a Wide Door for Faculty Organizing by Joseph W. Ambash     


In a stunning and far-reaching decision, the NLRB has opened the door to union organizing among faculty at thousands of private-sector institutions, both secular and religious.  The Board's majority decision in Pacific Lutheran University, issued in the face of powerful dissents, will inevitably spark controversy and ongoing litigation both about the legality of NLRB intrusion into the operation of religious institutions and the proper interpretation of the "managerial" status of faculty under the U.S. Supreme Court's historic Yeshiva University decision.


Pacific Lutheran University Case


The question before the NLRB in Pacific Lutheran University was whether a local of the Service Employees International Union could represent a unit of nontenure-eligible contingent faculty members employed by the university in Tacoma, Washington.  The university argued that, as a church-operated institution, it was exempt from NLRB jurisdiction and that its full-time contingent faculty were managerial employees excluded from representation under the Supreme Court's 1980 decision in Yeshiva University.


In reviewing the decision of its regional director, the NLRB took the opportunity to solicit amicus briefs about the broad issues of jurisdiction over all religious institutions and the proper analysis of managerial status of all faculty at private higher education institutions.  In its decision, the Board articulated new, more stringent, standards that will make it difficult for religious institutions to claim exemption from the National Labor Relations Act (NLRA) and for all private institutions to claim that their faculty are exempt from union organizing.  It held that the contingent faculty in question were entitled to organize.


Difficult New Test


In Yeshiva, the Supreme Court ruled that the faculty of that institution were "managerial employees" excluded from collective bargaining because they "formulate and effectuate management policies by expressing and making operative the decisions of their employer."  Controversy had existed in applying the Yeshiva standards in the 34 years since that case was decided.  Reviewing courts and others had criticized the NLRB for creating confusing standards that gave poor guidance to litigants.  Despite these concerns, the overwhelming majority of private-sector institutions in the country have relied on the principles of this case to maintain union-free status among their faculty.


In the Pacific Lutheran decision, the Board stated its new rule as follows:

  1. Where a party asserts that university faculty are managerial employees, the Board will examine the faculty's participation in the following areas of decision-making: academic programs, enrollment management, finances, academic policy, and personnel policies and decisions, giving greater weight to the first three areas than the last two areas;
  2. The Board interpreted the term "effective recommendations" to mean that those recommendations "must almost always be followed by the [college or university's] administration," and that they must "routinely become operative without independent review by the administration";
  3. The Board will then determine, in the context of the university's decision-making structure and the nature of the faculty's employment relationship with the university, whether the faculty actually control or make effective recommendations over those areas. If they do, the Board will find that they are managerial employees and, therefore, excluded from the act's protections.

In his thoughtful dissent, NLRB member Harry I. Johnson III pointed out the virtual impossibility of satisfying this new standard:


"... by increasing the burden of proof for what the Board considers to be "effective" recommendations, and by failing to consider the actual, diverse processes of university business operations and governance, the Board has raised the bar for establishing managerial status of faculty to an unattainable height, one beyond the reach even of Arete̕̕̕."


Member Johnson pointed out that the new requirement, that to be effective, recommendations "must almost always be followed by the administration," is an "overly onerous standard," which will result in fewer Board decisions conferring managerial status on faculty."   In addition, member Johnson criticized the Board majority's holding that faculty recommendations are not effective if they are subject to independent review. He pointed out that discounting internal review "seems to utterly disregard the realities of decision - and policymaking in complex organizations."


The dissent's observations underscore the uphill battle nearly any college or university will have in demonstrating that its faculty are "managerial" and therefore not subject to collective bargaining.


Jurisdiction Over Religious Institutions


The Board also ruled that it will exercise jurisdiction over religious institutions-and hence allow faculty organizing-except where:

  1. The college or university first demonstrates that it holds itself out as providing a religious educational environment;
  2. Once that threshold requirement is met, the college or university must then show that it holds out the faculty members it seeks to organize as performing a religious function. This requires a showing by the college or university that it holds out those faculty as performing a specific role in creating or maintaining the university's religious educational environment.

As member Johnson pointed out in his dissent, the Board's new standard, which requires a religious university to prove that it "holds out" its faculty "as performing a specific role in creating and maintaining" its religious educational environment, necessarily involves the government in the process of evaluating religious beliefs and practices, thereby improperly intruding into the Religious Clauses of the First Amendment.  This is particularly true because the majority decision requires a showing that faculty are required to serve a specific "religious function" - something that, of course, can vary widely from religion to religion. In Member Johnson's view, if the Pacific Lutheran standard is eventually appealed to the D.C. Court of Appeals, it will be overturned.


Take-Away for All Private Higher Education Institutions


The NLRB's decision-unless and until it is reversed or modified-will force nearly all private-sector institutions to reevaluate their vulnerability to union organizing among their faculty.  For institutions that view their faculty as truly "managerial" and not subject to organizing, the decision injects a new era of uncertainty about the fundamental relationship between faculty and administration.


Institutions should audit their administrative structure to determine the extent to which their faculty (whether regular or contingent) make "effective recommendations" which are "almost always" followed by the administration, without review.  This standard may be unattainable in the era of modern higher education.  Institutions who wish to maintain union-free status among their faculty should also train their administrators how to respond to organizing activities by understanding how union organizing works under the NLRA, recognizing organizing activities, and educating faculty to the pro's and con's of collective bargaining.


Religious universities likewise should audit their administrative structure to determine whether they "hold out" their faculty as serving specific religious functions.


All institutions should carefully monitor ongoing developments in this critical area.


NLRB Decision Strengthens Organizing Rights of Private-Sector Faculty by Aaron Nisenson   


On December 20, 2014, the National Labor Relations Board published a significant decision involving the organizing rights of private-sector faculty members. In Pacific Lutheran University, the Board modified the standards used to determine two important issues affecting the ability of faculty members at private-sector higher education institutions to unionize under the National Labor Relations Act: first, whether certain institutions and their faculty members are exempted from coverage of the National Labor Relations Act due to their religious activities; and second, whether certain faculty members are managers, who are excluded from protection of the act. In addressing this second issue, the board specifically highlighted, as the AAUP had in an amicus brief submitted in the case, the increasing corporatization of the university.


The question of whether faculty members in religious institutions are subject to jurisdiction and coverage of the act has long been a significant issue, with the Supreme Court's 1979 decision in Catholic Bishop serving as the foundation for any analysis. In Pacific Lutheran University, the Board established a two-part test for determining jurisdiction. First, whether "as a threshold matter, [the university] holds itself out as providing a religious educational environment"; and if so, then, second, whether "it holds out the petitioned-for faculty members as performing a specific role in creating or maintaining the school's religious educational environment.


The employer and its supporters argued that only the threshold question of whether the university was a bona fide religious institution was relevant, in which case the act would not apply to any faculty members.  The Board responded that this argument "overreaches because it focuses solely on the nature of the institution, without considering whether the petitioned-for faculty members act in support of the school's religious mission."  Therefore, the Board established a standard that examines whether faculty members play a role in supporting the school's religious environment.


In so doing, the Board recognized concerns that inquiry into faculty members' individual duties in religious institutions may involve examining the institution's religious beliefs, which could intrude on the institution's First Amendment rights.  To avoid this issue the new standard focuses on what the institution "holds out" with respect to faculty members.  The Board explained, "We shall decline jurisdiction if the university 'holds out' its faculty members, in communications to current or potential students and faculty members, and the community at large, as performing a specific role in creating or maintaining the university's religious purpose or mission."


The Board also found that that faculty must be "held out as performing a specific religious function," such as integrating the institution's religious teachings into coursework or engaging in religious indoctrination (emphasis in original).  This would not be satisfied by general statements that faculty are to support religious goals, or that they must adhere to an institution's commitment to diversity or academic freedom.


Applying this standard, the Board found that while Pacific Lutheran University held itself out as providing a religious educational environment, the petitioned-for faculty members were not performing a specific religious function.  Therefore, the Board asserted jurisdiction and turned to the question of whether certain of the faculty members were managerial employees.


This second question arises from the Supreme Court's decision in Yeshiva, where the Court found that in certain circumstances faculty may be considered "managers" who are excluded from the protections of the act.  The Board noted that the application of Yeshiva previously involved an open-ended and uncertain set of criteria for making decisions regarding whether faculty were managers. This led to significant complications in determining whether the test was met and created uncertainty for all of the parties.


Further, in explaining the need for the new standard, the Board specifically highlighted, as AAUP had in our amicus brief, the increasing corporatization of the university. The Board stated, "Indeed our experience applying Yeshiva has generally shown that colleges and universities are increasingly run by administrators, which has the effect of concentrating and centering authority away from the faculty in a way that was contemplated in Yeshiva, but found not to exist at Yeshiva University itself.  Such considerations are relevant to our assessment of whether the faculty constitute managerial employees."


In Pacific Lutheran, the Board sought to create a simpler framework for determining whether faculty members served as managers.  The Board explained that under the new standard, "where a party asserts that university faculty are managerial employees, we will examine the faculty's participation in the following areas of decision making: academic programs, enrollment management, finances, academic policy, and personnel policies and decisions."  The Board will give greater weight to the first three areas, as these are "areas of policy making that affect the university as whole."  The Board "will then determine, in the context of the university's decision making structure and the nature of the faculty's employment relationship with the university, whether the faculty actually control or make effective recommendation over those areas. If they do, we will find that they are managerial employees and, therefore, excluded from the Act's protections."


The Board emphasized that to be found managers, faculty must in fact have actual control or make effective recommendations over policy areas.  This requires that "the party asserting managerial status must prove actual-rather than mere paper-authority. . . . A faculty handbook may state that the faculty has authority over or responsibility for a particular decision-making area, but it must be demonstrated that the faculty exercises such authority in fact."  Proof requires "specific evidence or testimony regarding the nature and number of faculty decisions or recommendations in a particular decision making area, and the subsequent review of those decisions or recommendations, if any, by the university administration prior to implementation, rather than mere conclusory assertions that decisions or recommendations are generally followed." Further, the Board used strong language in defining "effective" as meaning that "recommendations must almost always be followed by the administration" or "routinely become operative without independent review by the administration."


NLRB Remands Five Cases Following Pacific Lutheran Decision

On February 3, 2015, the NLRB Board issued decisions in three cases that involve issues related to the Pacific Lutheran decision: Seattle University, Case No. 19-RC-122863, Saint Xavier University Case No. 13-RC-022025  and Manhattan College, Case No. 02-RC-023543.  In Seattle University, the school objected to NLRB jurisdiction under Catholic Bishop and asserts that the at-issue faculty are managerial under Yeshiva.  In the other two cases, the university and the college have objected to NLRB jurisdiction on the grounds that they are religious institutions.  


Instead of determining each case by applying the revised standards from Pacific Lutheran to the facts in the respective records, the NLRB Board remanded the cases back to the NLRB Region offices where the cases originated.  Each Regional Director now has the discretion to allow the parties to brief the issues in light of the Pacific Lutheran decision based on the existing record.  Alternatively, the Regional Directors can order the reopening of the record for purposes of permitting the parties to present additional evidence.     


On February 12, 2015, the NLRB Board issued decisions in two other cases involving university objections to NLRB jurisdiction based on the holding in Catholic Bishop: Duquesne University of the Holy Spirit, Case No. 06-RC-080933, and Saint Xavier University, Case No. 13-RC-092296.  In both cases, the NLRB vacated its prior orders granting petitions for review and remanded the cases to the NLRB Region offices for appropriate action consistent with the Pacific Lutheran decision.    


There are two other cases pending at the NLRB Board that raise issues under Pacific Lutheran, which have not been remanded at this time: Point Park University, Case No 06-RC-012276 (managerial status of faculty under Yeshiva); and Islamic Saudi Academy, Case No. 05-RC-080474(objection to NLRB jurisdiction under Catholic Bishop).

Pacific Lutheran Decision to be Subject of Cornell Panel Discussion
On February 26, 2015, the National Center will be participating in a panel discussion concerning the impact and implications of the Pacific Lutheran decision at Cornell University.  The event is sponsored by the Cornell Law School Labor Law Clinic and The Worker Institute at Cornell.  Click here for more information.
NLRB Region Director 2 Dismisses UAW Representation Petitions for Columbia University Graduate Assistants and The New School Student Employees
Columbia University, Case No. 02-RC-143012

The New School, Case No. 02-RC-143009     


On February 6, 2015, NLRB Region 2 Director Karen P. Fernbach issued decisions dismissing representation petitions filed by UAW affiliates seeking to unionize graduate assistants and other students who provide instructional services at Columbia University and at the New School.  Both petitions were filed as test cases aimed at having the NLRB Board reconsider its holding in Brown University, 342 NLRB 483 (2004) that graduate students were not "employees" for purpose of Section 2(3) of the National Labor Relations Act (NLRA).    


In dismissing the petitions by the Graduate Workers of Columbia-GWC, UAW and Student Employees at The New School - SENS/UAW, Regional Director Fernbach explained that she was constrained by the NLRB Board's decision in Brown University.  In each of her decisions, Regional Director Fernbach stated: 


"Although I recognize that the Petitioner is seeking to have the Board reconsider Brown, it is improper for me to ignore Board precedent.  While the Petitioner's argument that the Board has remanded similar cases suggests that the Board would likely remand the instant case, I am, nonetheless, constrained by current Board precedent.  In the event that the Board agrees with the Petitioner, development of an efficient and complete record would be facilitated by a remand from the Board setting forth the factors and evidence that they wish to be considered.  As the Employer noted, reconsideration of current law is a decision for the Board."


It is likely that the Graduate Workers of Columbia-GWC, UAW and the Student Employees at The New School - SENS/UAW will seek review from the NLRB Board of the orders dismissing their petitions.  If such review is granted, the cases might set the stage for a comprehensive reconsideration of the Brown University decision.  It should be noted the efficacy and applicability of Brown University is already pending before the NLRB Board in Northwestern University, Case No. 13-RC-121359, where the Board issued a notice on May 12, 2014 soliciting amicus briefs.  The primary issue in Northwestern University is whether NCAA scholarship football players are entitled to union representation under the NLRA.
Boston University Part-Time Faculty Vote in Favor of Unionization
Boston University,  Case No. 01-RC-13974

A tally of the mail ballots concerning the unionization effort by part-time faculty at Boston University was conducted by NLRB Region 1 on February 4, 2015.  Of the approximate 799 faculty members determined to be in the unit, 319  voted in favor of unionization, and 158 voted against.  Seven ballots were voided and ten ballots challenged.  Unless objections are filed regarding the conduct of the election, a certification should be issued shortly for the following bargaining unit at Boston University: 


All part-time graduate and undergraduate faculty (adjuncts, part-time lecturers, lecturers, part-time instructors, or instructors) employed by Boston University at its Massachusetts campuses to teach at least one credit bearing course (including hybrid and blended courses) in a degree-granting program, and who are compensated on a per course or per hour basis but excluding all tenure or tenure-track faculty; full-time faculty; visiting or contract faculty; School of Medicine faculty (except Division of Graduate Medical Sciences); School of Dental Medicine faculty; deans, provosts, administrators, program coordinators, program directors, department chairs, graduate assistants, graduate students who teach only courses pursuant to a stipend, athletic coaches and faculty who teach only on line, courses at non-Massachusetts campuses, non-degree granting courses (including the Center for Professional Education and Center for English Language and Orientation Programs), and/or courses as a teaching supervisor; all other employees employed by the University including those who teach a class or course and are separately compensated for such teaching; and managers, confidential employees, guards and supervisors as defined by the Act.


ALJ Recommends Moraine Valley CC Adjunct Leader Be Reinstated

In our November 2014 E-Note, we reported on a decision by the United States Court of Appeals for the Seventh Circuit in Meade v. Moraine Valley Community College reinstating a federal lawsuit by Robin Meade, who was a contingent faculty member at Moraine Valley Community College (Moraine Valley) in Illinois, and the president of the Moraine Valley Adjunct Faculty Organization (MVAFO).  In her lawsuit, Meade charged that her termination constituted unlawful retaliation under the First Amendment and violated her right to due process of law.      


Meade was terminated after sending a letter in her capacity as MVAFO president to the League for Innovation in the Community College (LICC) criticizing the treatment of Moraine Valley adjunct faculty, the college's lack of innovation toward the adjunct faculty, and the impact of the college's actions on its students.  In her letter, Meade informed LICC that she had refused Moraine Valley's request that she support its reappointment to the LICC board. Two days after sending the letter, Meade received a termination notice citing the content of her letter as the basis for the discharge.  


Following her termination, Meade commenced her federal lawsuit claiming unlawful retaliation under the First Amendment and a denial of due process of law.  In addition, MVAFO pursued an unfair labor practice charge at the Illinois Educational Labor Relations Board alleging, inter alia, that her termination violated Sections 14(a)(1) and 14 (a)(3) of the Illinois Educational Labor Relations Act (IELRA) because the letter to LICC constituted protected activity.  Sections 14(a)(1) and 14 (a)(3) of IERA prohibit an educational employer from "Interfering, restraining or coercing employees in the exercise of the rights guaranteed under this Act" and "Discriminating in regard to hire or tenure of employment or any term or condition of employment to encourage or discourage membership in any employee organization."   


The simultaneous pursuit of constitutional and statutory claims on behalf of Meade in two forums provides an opportunity to highlight that the certain conduct in public sector employment can be protected under both the First Amendment and under a state collective bargaining law.  However, the legal standards and the applicable procedures for each claim are distinct. 


Differences between First Amendment Claims and Unfair Labor Practice Claims


The First Amendment affords certain free speech rights to a public employee to speak out as a citizen on issues of public concern, which is balanced against the public employer's responsibility to provide efficient governmental services.  Notably, the First Amendment is applicable to public employees whether or not they are covered by a public sector collective bargaining law.


The rules applicable to a litigated First Amendment free speech claim are substantially different from an administrative claim under a collective bargaining statute.  The scope of protected activities under a collective bargaining law is far greater than that under the First Amendment.  For example, a charging party in an unfair labor practice charge does not have to prove that the at-issue activity touched on a broader public issue in order for it to be protected.  An unfair labor practice charge is determined through an administrative process by officials responsible for enforcing the collective bargaining law. In contrast, the legal issue of whether conduct is protected under the First Amendment is determined by a federal judge. 


A Comparison of Results in Claims Related to Meade's Actions


On October 30, 2014, the United States Court of Appeals for the Seventh Circuit reversed a lower court's decision to dismiss Meade's lawsuit.  The appellate court concluded that her complaint alleged sufficient facts to state a claim that the college violated the First Amendment when it terminated her for speaking out on an issue of public concern.  The court also reinstated her claim that she was terminated without due process of law in violation of the Fourteenth Amendment.  Click her for court decision.  Following the appellate procedural ruling, the substance of Meade's constitutional claims will now be adjudicated by a federal trial court.


On January 22, 2015, Illinois Educational Labor Relations Board (IELRB) Administrative Law Judge (ALJ) Ellen Strizak issued a recommended decision finding that the college violated IERA by terminating Meade because her letter constituted protected activity under the statute and because the college did not dispute that Meade was terminated because of the letter.  In addition, the ALJ recommended that an order be issued directing the college to reinstate Meade to her adjunct faculty position with back wages.


In the recommended decision and order, the ALJ rejected the college's claim that the letter lost statutory protections because it included allegedly false representations and was sent in bad faith.  As the ALJ noted, the scope of protected activity under collective bargaining statutes is quite broad.  Merely inaccurate statements are protected unless an employer demonstrates that the employee's comments were deliberately intended to falsify or were maliciously aimed at injuring the employer.


The college has the right to challenge the ALJ's decision and order by filing written exceptions to the IELRB Board.  The final outcome of those exceptions may impact the results and remedies, if any, in Meade's federal lawsuit.

Court Upholds Two Units at University of Illinois at Urbana-Champaign
Bd of Trustees of University of Illinois v. Educational Labor Relations Board

On January 20, 2015, an Illinois appeals court rejected a legal challenge by the University of Illinois to certifications of representatives by the Illinois Educational Labor Relations Board (IELRB) for separate bargaining units involving high school teaching associates and non-tenure track faculty on the Urbana-Champaign campus.

In the first representation case, the Illinois Education Association was certified to represent a unit comprised of 34 full-time and regularly employed part-time teaching associates employed at University of Illinois Laboratory High School (Uni High).  In the second, the Campus Faculty Association, AFT-AAUP was certified by IELRB to represent a unit of approximately 479 non- tenure track faculty teaching or researching at Urbana-Champaign.  IELRB concluded a separate unit for the Uni High teaching associates was appropriate because it is a public high school that functions separate from the university's other operations.

In rejecting the university's appeal, the appellate court found that there was clear and convincing evidence in the administrative record to support the IELRB's decision to certify two separate units rather than a combined unit of Uni High teaching associates and non-tenure track faculty.  Click here for decision.


The National Center Welcomes Doctoral Student Intern Damon A. Davis

The National Center is pleased to welcome Damon A. Davis as a doctoral student intern.  Mr. Davis is a doctoral student in the Educational Leadership and Research Methodology (ELRM) program at Florida Atlantic University (FAU) Davie Campus.  He earned his M.Ed. degree and his bachelor's degree in Health Service Administration and Social Science from FAU.


For the past 16 years, Mr. Davis has served as a Counselor at Broward College located in Ft. Lauderdale, Florida.  During this time, he has also served as president of the United Faculty of Florida (UFF) Broward College Chapter, Collective Bargaining Team, Florida AFL-CIO Executive Board, and the Florida Education Association Governance Board. 


Donate to Support the National Center's Work and Mission

On-line contributions to the National Center can be made on our website.  Donations enable the National Center to enhance its programming, publications and initiatives.  On-line contributions can be made at the Hunter College Foundation's website.  At the website, select the National Center for Collective Bargaining Fund in the "Give To" drop down menu.  Click here to donate to the National Center. 


Volume 6, Journal of Collective Bargaining in the Academy is Available
Journal of CBA Logo
The National Center is pleased to announce publication of Volume 6 of the Journal of Collective Bargaining in the Academy, our open access, peer-review on-line journal.  We thank the journal's co-editors, Jeffrey Cross, Eastern Illinois University, and Steve Hicks, Association of Pennsylvania State Colleges and University Faculties, for their leadership and contributions to the journal.

Volume 6 includes two opinion pieces, one by former National Center Executive Director Richard Boris.  It also includes three scholarly articles: The Impact of Unionization on University Performance by Mark Cassell and Odeh Halaseh; Post-Recession CBAs: A Study of Wage Increases in the Agreements of Four State-wide Faculty Unions by Steve Hicks; and Academic Collective Bargaining: Patterns and Trends by Curtis R. Sproul, Neil Bucklew and Jeffrey D. Houghton.  Lastly, the volume includes a practitioner's perspective by Amy L. Rosenberger with respect to the NLRB representation case involving Northwestern University scholarship football players. Click here for JCBA, Vol. 6.

We encourage scholars, practitioners and students in the fields of collective bargaining, labor representation and labor relations to submit articles for publication in future volumes of the Journal of Collective Bargaining in the Academy.  The journal is hosted by the Booth Library, Eastern Illinois University. 
National Center for the Study of Collective Bargaining in Higher Education and the Professions 
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