Holding that a May 1990 statute deferring state employees' salary payments was "in no way `necessary' to the achievement of the [state legislature's] stated goals"
In Fraser Johnston Co. v. NLRB, 469 F.2d 1259 (9th Cir. 1972), the Board found that the employer violated § 8(a)(2) by improperly recognizing a union as the bargaining representative at a time when the bargaining unit did not represent a substantial employee complement.