The D.C. Court of Appeals upheld Friday the National Labor Relations Board’s Specialty Healthcare ruling, which made it easier for unions to form smaller collective bargaining units. The 2011 decision by the NLRB opened the union organizing flood gates in many ways and gave birth to the notion of micro-unions. The new standard established by the 2011 NLRB decision provides a much lower threshold for a union to establish a “community of interest” within a company’s workforce and thereby authorize a union representation election. Previously, the “pragmatic” community of interest standard set in the Park Manor Care Center ruling, required an “overwhelming community of interest”, which significantly broadened the universe of employees whose votes had to be considered. Although a further appeal to the United States Supreme Court (SCOTUS) may still be in the works, a unanimous decision by a three-judge panel of the DC Appellate Court is a significant blow to efforts to resurrect the Park Manor Care standard.