Addressed whether non-tenure-track faculty of a private university's school of art and design had the right to join a labor union. The university contended that these full- and part-time faculty members lacked a protected right to unionize because they were, in effect, managerial employees. Granting the university's petition for review in part, the D.C. Circuit held that one aspect of the National Labor Relations Board's decision on this question conflicted with Supreme Court precedent.