To say the National Labor Relations Board (NLRB) has been on a roller coaster ride over the past few months may be an understatement.

The summer started with the Supreme Court granting cert to an administration request for review of Noel Canning, the first of several appeals court decisions that effectively put the NLRB out of business by declaring the President’s recess appointments of board members invalid. The high court’s action put on hold, pending a ruling next spring, a number of board actions invalidated by the circuit courts.