The Regional Director for Region 13 of the National Labor Relations Board (NLRB) held today that all grant-in-aid scholarship players for Northwestern University's football team are "employees" under the National Labor Relations Act. The decision went to great lengths to distinguish the standards articulated in the 2004 decision in Brown University, which determined that graduate assistants were not "employees." It also resembled the NLRB’s analysis in the New York University decision of October 31, 2000, which the Brown University decision specifically overruled. Northwestern has stated that it is appealing the decision to the full NLRB in Washington, D.C.