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NLRB Officials Ratify Agency Actions Taken During Period When Supreme Court Held Board Members Were Not Validly Appointed

On July 18, 2014, the National Labor Relations Board unanimously ratified all administrative, personnel, and procurement matters taken by the Board from January 4, 2012 to August 5, 2013.  The Supreme Court held in NLRB v. Noel Canning that the Board Members appointed on January 4, 2012 were not validly appointed.  The Board regained a quorum on August 5, 2013.  From January 4, 2012 to August 5, 2013, the Board acted on various matters including the appointment of various Regional Directors, Administrative Law Judges, and restructurings of regional and headquarters offices.  The Board has now ratified these actions to remove any question concerning the validity of actions undertaken during that period.

In addition, the Board has expressly authorized the following actions:


  • The selection of Dennis Walsh as Regional Director for Region 4 (Philadelphia);
  • The selection of Margaret Diaz as Regional Director for Region 12 (Tampa);
  • The selection of Mori Rubin as Regional Director for Region 31 (Los Angeles);
  • The selection of Kenneth Chu, Christine Dibble, Melissa Olivero, Susan Flynn, and Donna Dawson as Administrative Law Judges;
  • The restructuring of various Field Offices;
  • The restructuring of Headquarters’ Offices.

On July 30, 2014, following the Board’s authorization, Regional Directors Walsh, Diaz, and Rubin ratified all actions taken by them or on their behalf from the dates of their initial appointments and July 18, 2014.  These ratifications include all personnel and administrative decisions, all actions in representation case matters, and all actions in unfair labor practice cases. 

 The July 18, 2014 Minute of Board Action can be viewed here.


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