Bush has nominated Ronald Meisburg, who as a recess appointment has served as a reliable anti-union vote on defining legal standards of employer deviancy down and eroding legal protections for workers, to serve four years on the National Labor Relations Board. From the Labor Law Blog:

During his recess appointment, Member Meisburg consistently sided with his Republican colleagues over his Democratic counterparts in cases involving important policy issues. See Harborside Healthcare Inc., 343 NLRB No. 100 (2004) (articulating standard for prounion supervisory conduct and finding that supervisors engaged in objectionable conduct by soliciting authorization cards); Crown Bolt Inc., 343 NLRB No. 86 (2004) (refusing to presume dissemination of plant closure threats); Oakwood Care Center, 343 NLRB No. 76 (2004) (overruling Clinton Board decision on user and user/supplier employee units); Brown University, 342 NLRB No. 42 (2004) (holding that graduate assistants are not statutory employees); Dana Corp., 341 NLRB No. 150 (2004) (granting review to determine whether to maintain the voluntary recognition bar); IBM Corp., 341 NLRB No. 148 (2004) (holding that nonunion employees are not entitled to a coworker at investigatory meeting). On the other hand, Member Meisburg was the Republican most likely to break from his party colleagues and join a Democrat to find that an employer violated the Act. These cases turned more on their facts than on an issue of law.