In 2000, the NLRB reversed its decision in M.S. Sturgis in Oakwood Care Center and ruled that full-time employees of one employer could not be in the same bargaining unit as employees who were jointly employed.

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In 2000, the NLRB in M.S. Sturgis, Inc., ruled that employees solely employed by an employer and those jointly employed (such as through a staffing agency) can be in the same bargaining unit without the consent of the employers, a decision that was later reversed in Oakwood Care Center (2004).

In 2000, the NLRB Reversed Its Decision in M