On March 29, 2000, an administrative law judge of the National Labor Relations Board approved a settlement between the NLRB and Yale University, which resolved unfair labor practices charges made against the University by its Graduate Employees and Student Organization. This decision, however, did not resolve the underlying question of whether graduate teaching assistants are employees under the National Labor Relations Act. This Note analyzes recent cases concerning the unionization of graduate student teaching assistants at. private universities and colleges. This Note argues that the NLRB's application of a "compensated services" test to teaching assistants is correct and that the public policy arguments against collective bargaining for teaching assistants are based on flawed conceptions of the university, the work teaching assistants do, and the purposes of the National Labor Relations Act.