Denying a motion for reconsideration, the National Labor Relations Board recently affirmed its decision in American Baptist Homes of the West d/b/a Piedmont Gardens, addressing the relevance of an employer’s motive in hiring permanent replacement workers for economic strikers. 364 NLRB No. 95 (Aug. 24, 2016). As a result, in cases involving allegations that an employer unlawfully hired permanent replacements, motivation will be a focal point of any investigation, and any “retaliatory” conduct by an employer in response to economic strikers could violate the National Labor Relations Act and require that the employer pay full back pay to permanently replaced economic strikers.