Brown University, NLRB No. 1-RC-21368

Last week, the NLRB handed down a decision reversing their decision in NYU holding that graduate students are "employees" at private universities (NLRA doesn't cover state employers.)
The central rationale seems to be that the relationship between students and the univeristy is "educational" and not "economic." (Does this problematize post-doc fellowship appointments, etc.? are professors on tenure-track "primarily economic" in their relationship vis-a-vis a university?)