Overruling a 2016 decision, the National Labor Relations Board held that employers do not have a duty to bargain with a newly certified union before imposing serious discipline on individual union-represented employees who are not yet covered by a collective bargaining agreement, as long as the discipline is materially consistent with the employer's established policy or practice. 800 River Road Operating Company, LLC, 369 NLRB No. 109 (6/23/20).