Takeaways

• Recently selected acting GC William Cowen’s Memo 25-05 rescinds dozens of his predecessor’s expansive and novel enforcement priorities.
• However, recent decisions expanding employee rights remain in effect — although they may be reversed by courts or a future Board.
• Also, despite the Board lacking a quorum, the NLRB is not paralyzed for the foreseeable future, regional offices can continue to accept and process unfair labor practice charges and representation petitions, and regions can take action in federal court, including seeking Section 10(j) injunctive relief.

Related link

• GC 25-05 Rescission of Certain General Counsel Memoranda (press release)

Article

Significant changes have occurred at the National Labor Relations Board (NLRB) following President Donald Trump’s inauguration. On Jan. 27, 2025, he fired the NLRB’s general counsel (GC), Jennifer Abruzzo, and Board chairperson, Gwynne Wilcox. On Feb. 1, 2025, the president fired Jessica Rutter, who was Abruzzo’s deputy and became acting GC when Abruzzo was fired. On Feb. 1, 2025, President Trump selected William Cowen to serve as acting GC.

1. Who is William Cowen?

Except for a 10-year period in private practice (1992-2002), Cowen has a long history at the NLRB, where he held a wide variety of high-level positions, most recently, as the regional director in the NLRB’s Los Angeles Regional office (Region 21) (2016-2025). Previously, he served as the NLRB’s solicitor (2006 to 2016), executive assistant to...

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