This order is a result of UH Manoa faculty member Vickery Lebbin being denied a promotion in 2009 due to union activity. An arbitrator found that the UH administration discriminated. This is a timely decision as the 2010-11 Tenure and Promotion procedures are underway. This order makes clear that the administrative behavior exhibited in the Lebbin case is prohibited for all employees. UH is required to post a notice informing employees of this order within 30 days.