On August 26, 2026, National Labor Relations Board (NLRB) General Counsel Crystal S. Carey released Memorandum GC 26-04, “Further Guidance Regarding General Counsel Priorities.” The memo provides important insight into the general counsel’s enforcement and litigation priorities and identifies several recent NLRB decisions that her office intends to challenge.
The memorandum does not mandate submission of any case categories to the Division of Advice. Instead, Carey has identified specific legal positions on arguments her office intends to advance.
Key Precedents Challenged by the General Counsel
GC 26-04 identifies a number of significant NLRB decisions and doctrines that Carey has challenged and intends to challenge. Several of these issues have substantial practical implications for employers. For a full list of what the general counsel has requested or intends to request that the board revisit, see the memorandum.
1. Severance Agreements (and Other Employment Agreements)
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