Recently, the National Labor Relations Board signaled its willingness to overturn two Bush-era decisions on union representation. We previously outlined how the Obama-appointed Board, now chaired by Wilma Liebman, likely would reconsider and overrule the 2007 NLRB decision in Dana Corp., 351 NLRB 434 (2007), regarding employees' right to challenge the union's representation after a company's voluntary recognition of the labor union.