These include Alaska[13], California,[14] Connecticut,[15] Hawaii,[16] Illinois,[17] Maine,[18] Minnesota,[19] New York,[20] Oregon,[15] Vermont,[21] and Washington.
[22] J. Warren Madden, the NLRB's first chair had issued rulings which required employers to remain neutral during union organizing campaigns and elections.
[31][32][25]: 105, 331 In Babcock & Wilcox , 77 NLRB 577 (1948), the Board held that unions were permitted to equal time during captive audience meetings.
In Peerless Plywood Co.[39] Farmer, Rodgers, and Peterson agreed that employers may not hold captive audience meetings within 24 hours of a union representation election.
[34]: 137 Two years later, in Economic Machinery Co., Farmer led a unanimous board in holding that one-on-one conversations between the employer and employee about the union is inherently coercive.
[40] In April 2022, Jennifer Abruzzo, general counsel of the NLRB, issued a memorandum calling for the board to find captive audience meetings unlawful.