and Temple University unionized. Despite a state law explicitly denying graduate assistants from unionizing, the Washington PERB ruled graduate assistants at the University of Washington could unionize. The University of Rhode Island also unionized that year. Brown era (2004–2016) In 2004, the NLRB again reversed itself and prohibited Brown University and other private universities from unionizing. Unionization drives after 2004 are mostly characterized by a slowing of momentum in organizing activity, particularly in private universities. The NLRB's Brown decision in 2004 reversed the legal protections and collective bargaining rights that, under NYU, had covered graduate students in private universities. As a result, private university union drives have stalled in the courts in attempts to reverse the Brown decision. Graduate students in public universities, however, have continued to unionize. A ruling by the Illinois Court of Appeals permitted the University of Illinois Urbana-Champaign (2002), University of Illinois Chicago (2004), and University of Illinois Springfield (2006) and Southern Illinois University at Carbondale (2006) to unionize. The large California State University system, the third university system, unionized in 2006. Also in 2006, Western Michigan University teaching assistants unionized—the fourth Michigan university to do so. Central Michigan University graduate assistants are developed a union and signed their first contract in 2010. In 2014, more than 2,100 graduate assistants at the University of Connecticut won union recognition following one of the fastest organizing campaigns in graduate student unionization history. Following the NLRB's Brown (2004) decision, NYU refused to bargain with the NYU graduate union after the expiration of their contract in 2005. Despite a 2005–06 strike, NYU graduate student employees union were not able to obtain union recognition. In April 2010, more than 1,000 NYU graduate assistants again filed an election petition with the NLRB. NLRB Acting Regional 2 Director Elbert F. Tellem denied the petition, deferring to the NLRB's 2004 decision in Brown University. But in language highly critical of Brown, Tellem observed that "The instant record clearly shows that these graduate assistants are performing services under the control and direction of" New York University "for which they are compensated. It is also clear on the record that these services remain an integral component of graduate education." Tellem criticized Brown University for being "premised on a university setting as it existed 30 years ago", and said that "The graduates have a dual relationship with the employer which does not necessarily preclude a finding of