In Midwest Division-MMC, LLC, d/b/a/ Menorah Medical Center v. NLRB, 867 F.3d 1288 (D.C. Cir. Aug. 18, 2017), the Circuit Court of Appeals for the District of Columbia held that nurses do not have a right to union representation during voluntary investigatory hearings. The circuit court’s decision reversed the National Labor Relations Board’s (“NLRB”) expansive…

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