This Union Drive Could Have Been an Email: Adapting Representation Elections to the Internet Age Under the NLRA

Document Type

Response or Comment

Publication Date

2025

Journal

American University Administrative Law Review

Volume

77

Issue

1

Abstract

During its 2024 Session, the Supreme Court of the United States sent shockwaves throughout the field of administrative law. Its decision in Loper Bright Enterprises v. Raimondo dramatically changed the level of deference owed to federal administrative agencies. Further, the holding of SEC v. Jarkesy imposed an obligation to try some cases concerning administrative penalties “sound[ing] in both law and equity” in an Article III court. These decisions all but guarantee an explosion of litigation in federal court concerning administrative rules, adjudication, and governance. Moving forward, administrative agencies must severely increase their budget allowances for federal litigation, take prophylactic measures to avoid prolonged judicial review, and prepare to slow down their policymaking and governing processes to account for time spent in federal court. The National Labor Relations Board (NLRB or the Board) stands to bear a comparatively increased burden from these decisions as it already operates under severe budget constraints and a progressively increasing load of outstanding cases year over year.

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