and universities in the United States are covered by the National Labor Relations Act (NLRA). Initially, the National Labor Relations Board (NLRB) rejected all private university employees including academic employees from being protected by the NLRA. In the Trustees of Columbia (1951) decision, the NLRB held that the act did not have jurisdiction in private universities because universities focus primarily on education and are not associated with significant commercial activity. However, two decades later in Cornell v NLRB (1970), the NLRB reversed Columbia, holding that due to changing economic realities and difficulties in distinguishing between commercial and noncommercial activities in private universities, the NLRA covers employees in private education institutions. For the employee status of academic student employees, the NLRB's rulings have shifted in recent decades. In these decisions, the NLRB has grappled with two main conflicting legal arguments. The "primary purpose" approach holds that graduate students are not employees because the primary purpose of graduate students is to fulfill the role of a student rather than that of an employee. In contrast, the "compensated services" approach holds that graduate students are employees because they perform services for others and have distinct manager-worker relations with university administrators. The "primary purpose" doctrine was first applied to graduate students in Adelphi University and Adelphi University Chapter, American Association of University Professors (1972) (Adelphi University) decision, in which the NLRB rejected graduate teaching and research assistants from collectively bargaining with faculty. After years of rejecting employee status to graduate students, the NLRB overturned the Adelphi University (1972) decision. Under New York University and International Union, United Automobile Aerospace and Agricultural Implement Workers of America, AFL–CIO (2000) (NYU), the NLRB applied the "compensated services" legal approach, ruling for the first time that graduate students at private universities were considered employees, and hence protected by the NLRA. However, the NLRB later returned to its "primary purpose" approach in 2004 after a new Republican-appointed majority reversed NYU. In Brown University and International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, UAW AFL–CIO (2004) (Brown University), the NLRB's 3–2 majority ruled that graduate students in private universities are not considered employees. In recent years, NYU's graduate student union filed a case seeking to overturn Brown University, which in 2012 the NLRB announced that it would reconsider. However, NYU's graduate student union later agreed to withdraw its NLRB petition in return for union recognition by the