IBM Corp., 341 NLRB No. 148 (June 9, 2004)
In this far-reaching decision, the National Labor Relations Board overruled its own recent decision in Epilepsy Found. of N.E. Ohio, 331 NLRB 676 (2000), and held that employees who are not represented by a union are not entitled to have a coworker present during investigatory interviews. In this decision, the Board held that IBM