How the hell do non-profits fall under the jurisdiction of the NLRB? non-profits by definition rely mainly on donations to survive. How can you bind a non-profit to any agreement that fixes the amount of money that they must pay out to workers when their income is not guaranteed? So let's say the non-profit has a major shortfall in donations and can't meet it's obligations to the union, then what happens? Are they supposed to go out of business because of union demands? It is similar to the reason why you cannot levy property taxes against churches. As soon as they can no longer afford to pay them, the church land is confiscated and freedom of religion goes out the window as churches across the country become subject to seizure.