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For decades, both unionized and non-unionized employers have routinely included at-will employment provisions in their employee handbooks and other employment documents, ensuring that workers knew that their employment relationship was terminable at will by either party. Recently, in American Red Cross Arizona and Lois Hampton and Hyatt Hotels Corporation and United Here International Union, Region 28 of the National Labor Relations Board (NRLB), located in Arizona, has attempted to outlaw this common practice by finding such at-will provisions unlawful under the National Labor Relations Act (NLRA). 

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