private university. On December 17, 2014, graduate student unions affiliated with UAW at both Columbia University and The New School have filed petitions at the NLRB to overturn the Brown decision. Following the NLRB's 2016 Columbia University decision, student unionization in certified bargaining units grew by 14,820 members. Much of this growth was due to ten newly certified student employee unions at private universities, following NLRB elections at Harvard and the New School, as well as voluntary recognitions of graduate employee unions at Georgetown University and Brown University. History Beginnings (1960s–1979) Graduate student unionization began mostly in the late 1960s, influenced heavily by the New Left Movement and the UC Berkeley Free Speech Movement. The two movements sparked discussions on university democracy and students' relationship with the university. Throughout this period, only public university graduate students were able to form recognized unions. Although graduate students in private colleges were active in union organizing campaigns, they were greatly restricted by the Columbia (1951) and later Adelphi University (1972) decisions, which both barred the NLRA from protecting graduate students in private universities. The board ruled that graduate assistants were not employees since their relationship is primarily for learning purposes. Teaching assistants at Rutgers University and the City University of New York (CUNY) were the first to be included under a collective bargaining agreement. Rutgers and CUNY included graduate assistants with the faculty unionization contract. The University of Wisconsin–Madison's Teaching Assistants Association was the first to be recognized as an independent employee bargaining unit in 1969 and was granted a contract in 1970. At the same time, graduate assistants at the University of Michigan organized a union, which later won a contract in 1975. The next to unionize was the University of Oregon and three Florida universities: University of Florida, Florida A&M, and the University of South Florida. Florida was the first state to unionize where the union membership density in the state was below 15 percent. Decline and inactivity (1980–1989) Between 1981 and 1991, few universities recognized a graduate union—the quietest period of unionization. An exception was the University of Massachusetts Amherst, where 2,500 graduate assistants won recognition in November 1990 and a contract the following year covering teaching, research, and project assistants, and assistant residence directors. Teaching assistants at the University at Buffalo began a union campaign in 1975, but withdrew their petition to the State of New York Public Employee