seeks to make employees pay dues under a union security agreement, it must inform all workers that they have the legal right to remain a non-member of the union and to pay only such fees as may be used for collective bargaining purposes (and no more). Paperworkers Local 1033 (Weyerhaeuser Paper Co.) addressed issues which California Saw did not, and Truesdale and the board unanimously held that a union must inform all bargaining unit members (not just existing nonmembers) of their Beck rights and that they must inform all union members that they have the right to become a nonmember. In Canteen Co., 317 NLRB 1052 (1995), enf'd. 103 F.2d 1355 (7th Cir. 1997), Truesdale joined with the majority in a major new ruling on successorship. In Fall River Dyeing & Finishing Corp. v. NLRB, 482 U.S. 27 (1987), the Supreme Court had held that if a one company succeeds another, it has a duty to bargain with the previous company's union if there is a substantial continuity between the two companies and the new company retains at least 50 percent of the workforce. Joining an opinion written by Gould, Truesdale held that the duty to bargain was not sundered by the employer's decision to change wage rates or benefit levels. In Keeler Brass Automotive group, 317 NLRB 1110 (1995), Gould convinced Truesdale and Cohen to change their vote and form a five-member majority in holding that a grievance committee is not a labor organization under the NLRA and hence cannot be a "company union" (even if employer-dominated). In A.P.R.A. Fuel Oil Buyers Group, 320 NLRB 408 (1995), Truesdale joined with Gould against Democratic Member Peggy Browning to interpret the Supreme Court's ruling in Sure-Tan, Inc. v. NLRB, 467 U.S. 883 (1984). The Court had held in Sure-Tan that undocumented workers are entitled to back pay awards under the NLRA. In A.P.R.A. Fuel Oil, the collective bargaining agreement required the employer to reinstate laid-off workers first when it begins hiring again. If there were no dismissed workers available, then the employer was required to hire union-referred workers. The union asserted that this included undocumented workers. But Truesdale and the majority held that the board has no authority to force an employer to hire such undocumented workers. The baseball strike But his most important decision came in the 1994–95 Major League Baseball strike. Major League Baseball (MLB) and the Major League