her service. Truesdale defended Cracraft as utterly impartial, and said that the National Labor Relations Act's penalties were intended to be remedial and not punitive. In 1990, Truesdale oversaw a partial shutdown of NLRB operations. Truesdale identified a major budget shortfall in early August. By late August, Truesdale ordered a ban on all travel, and said all ULP hearings cancelled. Exceptions were made for cases involving picketing or were violence might break out. Truesdale even considered furloughing all NLRB workers for two to three days in September. During this period, Truesdale also pushed for the board to engage in a rulemaking regarding the Supreme Court's decision in Communications Workers of America v. Beck, 487 U.S. 735 (1988). In that decision, the Court held that, in a union security agreement, unions are authorized by statute to collect from non-members only those fees and dues necessary to perform its duties as a collective bargaining representative. The rights identified by the Court in Communications Workers of America v. Beck have since come to be known as "Beck rights." In October 1991, White House Counsel C. Boyden Gray began criticizing the board and then-chair James M. Stephens for not adequately enforcing workers' Beck rights. Stephens had already proposed at this time a rulemaking on the issue, and in October 1991 and May 1992 Stephens acceded to requests by White House staff to show them the rule so they could provide comments on it. In May 1992, for only the second time in its history, the National Labor Relations Board undertook a regulatory rulemaking aimed at resolving the divergent, complex issues raised by the Beck decision. On September 3, 1992, even though the public comment period on the rule had closed, the White House sent a memo to Executive Secretary Truesdale indicating that comments on the rule were coming from the White House, that these comments should not be made public, that the White House expected these comments to be incorporated into the rule, and that the White House wanted to see the final rule before it was published. Truesdale and the Board's Solicitor General, John Higgins, sent a memo to the board the following day outlining the White House's requests and positions. The Board voted 4-to-1 (with Member Dennis Devaney dissenting) not to consider or review the White House memo. The proposed rule issued on September 22, 1992. But after three and a half