NLRB Administrative Law Judge Raymond P. Green ruled that employers can agree to accept a union based on a card check procedure, and agree to remain neutral in union elections. See Heartland Industrial Partners and United Steelworkers of America, et al. NLRB Division of Judges, New York Branch Office, 34-CE-9, June 16, 2005. Union Wins Right to Use New Tool to Organize by Alison Grant, The Plain Dealer, July 6, 2005.