In Saint John's Health Center, 357 NLRB No. 170 (Dec. 30, 2011), one of he NLRB's final decisions before then-Member Craig Becker's recess appointment expired, the Board ruled by a margin of two to one that it was unlawful for Saint John's Health Center to prohibit registered nurses from wearing union ribbons in immediate patient care areas during a union organizing drive while at the same time allowing nurses to wear a ribbon the hospital endorsed stating, "Saint John's mission is patient safe care." In the same decision, the Board considered to what extent a healthcare provider may restrict employees from returning to the workplace when they are not on duty and not there to visit a patient. The Board ordered the hospital to rescind its "off-duty employee access policy," which the Board concluded effectively told employees that, "you may not enter the premises after your shift except when we say you can." To learn more about the decision and its implications for employers, please continue reading Littler's ASAP, Healthcare Employers May Not Selectively Prohibit Union Insignia in Patient Care Areas, by Eric Stevens and Jennifer Mora.