On February 14, 2025, the Acting General Counsel of the National Labor Relations Board (“NLRB”) William B. Cowen issued his first General Counsel Memorandum (“GC Memo”) GC 25-05 rescinding nearly all of the Biden administration General Counsel’s substantive prosecutorial guidance memos, which furthered a pro-union and pro-employee agenda. While these memoranda do not have the weight of law or regulation, they do set out the agency’s priorities and key interpretations of the National Labor Relations Act (“NLRA”).
