improve the speed with which decisions were issued. Third NLRB term, 1994–1996 Truesdale returned to his position as the board's executive secretary, but on December 23, 1994, President Clinton again named him to a recess appointment on the board. Truesdale replaced Dennis Devaney, a conservative Democrat appointed to the Board by President George H. W. Bush. This recess appointment lasted until January 3, 1996. According to Gould, Truesdale was a hard worker who produced decisions quickly, but who also adapted his views to changing political winds. He also overwhelmingly supported any request by the General Counsel for legal action to enforce the board's rulings. Gould and Truesdale clashed repeatedly on the role the board should play as well. Gould felt the chair should speak out publicly about pending labor law reform and should sponsor conferences on current issues in labor law to keep itself and the staff informed. But Truesdale advocated silence on pending legislation, and that the board should not create the appearance of partiality by sponsoring seminars. Truesdale played a key role in several important decisions during his term on the board. Among these were Makro, Inc., 316 NLRB 109 (1995) (better known as Loehmann's Plaza II), in which the board reversed a precedent (Makro, Inc., 305 N.L.R.B. 663 [1991], also known as Loehmann's Plaza I) established just four years earlier and denied union picketers the right to access an employer's property; Oakland Mall, 316 NLRB 1160 (1995), also known as Oakland Mall II, in which the board held that nonemployee handbilling on behalf of a labor union may not occur on an employer's property; Leslie Homes, Inc., 316 NLRB 123 (1995), aff'd Metropolitan District Council of Philadelphia and Vicinity United Brotherhood of Carpenters and Joiners of America, AFL-CIO v. NLRB, 68 F.3d 71 (3d. Cir. 1995), in which the board held that a union may not picket on land occupied by homes being sold by a real estate developer. He also voted with the majority in important cases (California Saw & Knife Works, 320 NLRB 224 [1995], Paperworkers Local 1033 (Weyerhaeuser Paper Co.), 320 NLRB 349 [1995]) involving the rights of workers who are not union members as established in Communications Workers of America v. Beck, 487 U.S. 735 (1988). California Saw was the NLRB's first ruling in the wake of the U.S. Supreme Court's decision in Beck. Truesdale and the majority held that whenever a union