New York construction-industry employers should be aware of a significant change to the state’s Paid Family Leave (“PFL”) law. On December 19, Governor Kathy Hochul signed Assembly Bill 4727 (“A4727”) into law, expanding PFL eligibility to many construction workers who work for multiple employers under a collective bargaining agreement each
Dixie Morrison
Dixie Morrison is an associate in the Labor & Employment Department and a member of the Employment Litigation & Arbitration Group. She is a member of the Discrimination, Harassment, & Title VII and the Labor-Management Relations practice groups.
Dixie assists clients across a variety of industries in litigation and arbitration relating to wrongful termination, discrimination, harassment, retaliation, wage and hour, trade secrets, breach of contract, and whistleblower matters in both the single-plaintiff and class and collective action contexts. She also maintains an active traditional labor and collective bargaining practice and regularly counsels employers on a diverse range of workplace issues.
Dixie earned her J.D. from Harvard Law School, where she was the Executive Editor of Submissions for the Journal of Sports and Entertainment Law. Dixie received her B.A., magna cum laude, from Pomona College. Prior to law school, she served as a labor and economic policy aide in the United States Senate.
A Uncommon Intervention May Signal Future SCOTUS Review of NLRB
On December 22, 2025, the U.S. Supreme Court stepped in to stay the Third Circuit’s enforcement of a National Labor Relations Board (“NLRB” or the “Board”) decision and order requiring the Pittsburgh Post-Gazette (the “Post-Gazette”) to bargain in good faith with the Newspaper Guild of Pittsburgh (the “Guild”) as well…
No Injunction for You: Third Circuit Rejects Employer Bid to Halt NLRB Case, Setting up Circuit Split
In a significant decision, the Third Circuit Court of Appeals held on December 3, 2025 that federal courts lack jurisdiction to issue injunctions that would halt ongoing National Labor Relations Board (“NLRB”) administrative proceedings—even when an employer frames its challenge as a constitutional attack on the NLRB’s structure.
The ruling…
Ninth Circuit Rejects SAG-AFTRA Vaccine Mandate Lawsuit
In an unpublished but nonetheless significant opinion, the Ninth Circuit recently affirmed the lower court’s dismissal of a consolidated lawsuit filed by SAG-AFTRA members against their union, finding the claims time-barred and preempted. In relevant part, the dispute was rooted in allegations that SAG-AFTRA, by negotiating a return-to-work agreement that…
Total Security Recall: Recent Decision May Lead to Reinstatement of Bargaining Requirement for Discipline Pre-CBA
A recent Administrative Law Judge ruling in Starbucks Corp.sets up a possibility for the National Labor Relations Board to reinstate an employer’s obligation to bargain with a union before imposing serious discretionary discipline in a newly-organized workplace before a first contract is agreed to—even when the discipline is…
Federal Appeals Court Partially Affirms Elimination of NLRB Rule, Hitting Fast-Forward Button on Representation Elections
A divided three-judge panel of the D.C. Circuit Court of Appeals partially affirmed a federal district court’s decision to vacate part of a rule issued by the National Labor Relations Board (the “Board”) in 2019 that eliminated several “quickie” representation election procedures established by a 2014 rule (the “2014 rule”).…
Special Delivery: NLRB Returns to Obama-Era Standard to Limit Employer Ability to Change a Proposed Bargaining Unit
The National Labor Relations Board continues its December precedent merry-go-round with a return to the Specialty Healthcare, 357 NLRB 934 (2011) (“Specialty Healthcare”) standards for bargaining unit determinations. In American Steel Construction, 372 NLRB No. 23, the Board overturned PCC Structurals, Inc., 365 NLRB No.…
NLRB Upholds “Successor Bar Doctrine,” Citing Labor Market Volatility
On June 28, 2022, the National Labor Relations Board (“NLRB”) voted to uphold the so-called “successor bar doctrine” in Hospital Menonita de Guyama, Inc. This doctrine provides incumbent unions with an irrebuttable presumption of majority support for at least six months after a change in employer ownership. Incumbent unions…