Scott Mayer
Scott Mayer's career trajectory — from Boeing Chief Labor Counsel to NLRB Member — represents a case study in revolving-door transitions between a major employer and the federal agency that adjudicates its labor disputes. His dossier documents the financial ties retained during the transition, the ethics framework governing recusal, and gaps in public transparency around compliance with those obligations.
Scott Andrew Mayer served as Boeing's Chief Labor Counsel from June 2022 through December 2025 — the company's lead attorney for NLRB litigation, union contract interpretation, and labor arbitrations 1. During that period, he represented Boeing as attorney of record in NLRB cases, including Case 19-CA-352164, a bad-faith bargaining charge filed in October 2024 2. Trump nominated Mayer to the National Labor Relations Board in July 2025; the Senate confirmed him on December 18, 2025, and he was sworn in January 7, 2026 1.
Mayer's financial disclosure at nomination listed Boeing stock valued at $5–25 million, employer equity of $100–250 million, unvested RSUs of $250–500 thousand, and other Boeing compensation, with his employment status listed as 'Present' 3. FEC records show 50 biweekly $50 contributions to The Boeing Company PAC from October 2023 through December 18, 2025 — his confirmation date — totaling $2,500, uninterrupted through his nomination, Senate hearing, and confirmation vote 4. At the October 1, 2025 HELP Committee hearing, Mayer testified he was 'not involved in the negotiations' and 'not serving as a representative to the company at the hearing,' while NLRB docket records listed him as Boeing's attorney of record in a case filed twelve months earlier 5.
His August 2025 ethics agreement requires divestiture of all Boeing stock within 90 days of confirmation — a deadline of approximately March 18, 2026 — along with a 2-year cooling period on Boeing matters tied to RSU vesting dates 6. As of March 2026, no recusal list for Mayer appears to have been published on nlrb.gov, despite the NLRB's 2019 Ethics Recusal Report establishing that as standard practice; records indicate he has been participating in Board decisions since his swearing-in 7.
Career Trajectory and Confirmation
Mayer's pre-government career was built entirely on the management side of labor law. He trained at Morgan Lewis & Bockius, one of the country's largest management-side labor practices, then moved through Blank Rome LLP and in-house counsel positions at Aramark, InterContinental Hotels Group (IHG), and MGM Resorts International before joining Boeing as Chief Labor Counsel in June 2022 1. His academic background — Cornell's School of Industrial and Labor Relations and Villanova Law — is the standard credentialing path for management-side NLRB practitioners. At Boeing, his portfolio covered NLRB litigation, union contract interpretation, labor arbitrations, and what Boeing termed 'positive employee relations strategy' 1.
Trump nominated Mayer on July 17, 2025. The Senate HELP Committee held his hearing on October 1, 2025, initially scheduled a vote that was subsequently withdrawn, then advanced him 12-11 on December 3, 2025. The Senate confirmed him December 18, 2025; he was sworn in January 7, 2026, with a term expiring December 16, 2029 1. The narrowness of the committee vote — and the fact that it required two attempts — reflected opposition from both Democratic members and Sen. Josh Hawley (R-MO), whose state was then experiencing an active IAM 837 strike at Boeing's St. Louis facility 5.
Mayer joins a Board reconstituted under the Trump administration. As of January 7, 2026, the NLRB's three seated members are David Prouty (Democrat, term expires August 2026), James Murphy (Republican, term expires December 2027), and Mayer (Republican, term expires December 2029). Murphy and Mayer hold a 2-1 Republican majority. When Prouty's term expires in August 2026, the Board will again drop below quorum unless a replacement is confirmed.
Financial Ties to Boeing
Mayer's financial disclosure at nomination listed retained Boeing compensation and equity in six categories: stock valued at $5–25 million, employer equity valued at $100–250 million, an executive supplemental savings plan, a 401(k), unvested RSUs valued at $250–500 thousand, and an anticipated bonus 3. At the time the disclosure was filed, his Boeing employment status was listed as 'Present,' meaning his financial exposure to Boeing's stock price and to Boeing's labor litigation outcomes was active during the confirmation process 3.
FEC records provide a second data set on the Boeing financial relationship. Mayer made 50 biweekly contributions of $50 each to The Boeing Company PAC between at least October 2023 and December 18, 2025, with employer listed as BOEING, Arlington, VA 4. The contribution series was unbroken: it continued through his July 17, 2025 nomination, his October 1, 2025 Senate hearing, his December 3, 2025 committee advancement, and ended on December 18, 2025 — his Senate confirmation date 4. Payroll-deduction PAC contributions of this regularity typically require employer payroll cooperation, suggesting Boeing's payroll infrastructure continued processing these contributions through his confirmation date.
NLRB Representation and Recusal Obligations
Mayer's transition from Boeing's NLRB representative to a seat on the NLRB is documented in the Board's own case dockets. He is listed as Boeing's attorney of record in Case 19-CA-352164 (The Boeing Company, Region 19, Seattle, filed October 7, 2024), an 8(a)(5) refusal to bargain and bad-faith bargaining charge, and in Case 16-CA-337549 (Region 16, San Antonio, filed March 6, 2024), an 8(a)(1) retaliation and discharge charge. Both cases closed via withdrawal 2. His last documented appearance as Boeing's NLRB representative predates his nomination by nine months.
At his October 1, 2025 Senate HELP Committee hearing, Mayer testified he was 'not involved in the negotiations' and 'not serving as a representative to the company at the hearing' in response to questions about the Boeing-IAM 837 strike 5. The NLRB case docket showing him as Boeing's representative in Case 19-CA-352164 — filed twelve months before the hearing — was publicly available at the time. Sen. Hawley's opposition to a nominee from his own party's president, on grounds of that nominee's corporate ties, was significant enough to narrow the committee vote to 12-11 and require a second vote attempt 5.
His August 28, 2025 ethics agreement (OGE-filed) contains five commitments: resignation from the Boeing Chief Labor Counsel role; forfeiture of unvested RSUs; divestiture of all Boeing stock within 90 days of confirmation (deadline approximately March 18, 2026); non-participation in Boeing matters until divestiture is complete absent a written waiver under 18 USC 208(b)(1); and a 2-year cooling period under 5 CFR 2635.503 running from each RSU vesting date 6. The rolling nature of RSU vesting schedules means specific recusal end-dates are unknown without access to his full vesting calendar, and analysis suggests the obligations may extend to 2027–2028 7.
As of March 2026, according to the NLRB's Board Member Recusal Lists page, only a July 2024 recusal list for member David Prouty is available 6 7. No recusal list for Mayer has been published, despite the NLRB's own 2019 Ethics Recusal Report establishing publication as the standard practice for all Board members. Weekly NLRB decision summaries — records indicate Mayer's name on published decisions since January 7, 2026, but without a public recusal list, external verification of his recusal practices is not possible 7.
All Connections
2 total
All Connections
2 totalBoeing Chief Labor Counsel (June 2022-Dec 2025), responsible for NLRB litigation. Now NLRB Member adjudicating Boeing matters.
NLRB Member sworn in Jan 7, 2026. Term expires Dec 16, 2029. Previously represented Boeing before the NLRB as Chief Labor Counsel.
All Findings
7 total
All Findings
7 totalfinancial (1)
FEC RECORDS: Mayer contributed $50 biweekly to The Boeing Company PAC from at least Oct 2023 through Dec 18, 2025 (his Senate confirmation date). This is payroll-deduction style recurring donation. Contributions continued uninterrupted through: his nomination (July 17, 2025), Senate hearing (Oct 1, 2025), and confirmation vote (Dec 18, 2025). Last recorded Boeing PAC contribution: Dec 18, 2025 — the day the Senate confirmed him. FEC records show employer as BOEING, Arlington VA. Total Boeing PAC contributions in dataset: $2,500 across 50 contributions from Oct 2023-Dec 2025.
relationship (1)
REVOLVING DOOR: Scott Mayer, former Boeing Chief Labor Counsel (2022-Present), now serves as Member of the National Labor Relations Board. Still listed as Present employee at Boeing. Retains Boeing holdings including $5-25M in stock, employer equity $100-250M, executive savings plan, 401k, unvested RSUs, and anticipated bonus. NLRB directly adjudicates Boeing labor disputes — Boeing has been subject to multiple high-profile NLRB proceedings including union organizing at its SC plant. This is the most direct possible conflict: Boeing's labor lawyer now sits on the board that rules on Boeing labor cases.
Position: Chief Labor Counsel at Boeing (6/2022-Present). Now: Member, NLRB. Holdings: Boeing stock $5-25M, Boeing employer equity $100-250M, Boeing Executive Supplemental Savings Plan, Boeing 401k, Boeing unvested RSUs $250-500K, Boeing anticipated bonus. NLRB has ruled on multiple Boeing labor cases including SC plant union organizing (2011) and machinist strikes. Boeing's labor lawyer now adjudicates labor cases against Boeing and peers. Still listed as Present employee.
legal (3)
ETHICS AGREEMENT: Mayer's Aug 28, 2025 ethics agreement to NLRB Designated Agency Ethics Official (filed with OGE) commits to: (1) resign from Boeing chief labor counsel role, (2) forfeit unvested RSUs, (3) divest all Boeing stock within 90 days of confirmation (deadline ~March 18, 2026), (4) not participate in Boeing matters until divestiture complete unless granted written waiver under 18 USC 208(b)(1), (5) 2-year cooling period under 5 CFR 2635.503 after RSU vesting during which he will not participate in Boeing matters. Critical gap: no published recusal list for Mayer on nlrb.gov as of March 2026, despite recusal lists being standard for all board members.
NLRB CASE REPRESENTATIVE: Mayer is listed as Boeing's legal representative in NLRB Case 19-CA-352164 (The Boeing Company, filed Oct 7, 2024, Seattle WA, Region 19), an 8(a)(5) refusal to bargain/bad faith bargaining charge. Also listed as Boeing representative in Case 16-CA-337549 (filed March 6, 2024, San Antonio TX), an 8(a)(1) retaliation/discharge charge. Both cases closed via withdrawal. Mayer was actively representing Boeing before the NLRB while being considered for a seat on the Board — he represented the company in NLRB litigation as recently as October 2024, less than a year before his nomination.
DIVESTITURE TIMELINE RISK: Mayer's 90-day divestiture deadline from Dec 18, 2025 confirmation falls around March 18, 2026. He has been participating in NLRB decisions since Jan 7, 2026 (every weekly summary shows Prouty, Murphy, Mayer on all published decisions). His ethics agreement allows participation in non-Boeing matters during the divestiture period, but the 2-year cooling period under 5 CFR 2635.503 runs from RSU vesting dates — meaning some Boeing recusal obligations may extend to 2027-2028 depending on vesting schedules. No public recusal list has been published for Mayer on nlrb.gov despite the NLRB's own 2019 Ethics Recusal Report requiring such lists. Only Prouty's July 2024 recusal list is available. This opacity makes it impossible for the public to verify whether Mayer is properly recusing from Boeing-adjacent matters.
intelligence (2)
TIMELINE: Scott Mayer served as Boeing Chief Labor Counsel from June 2022 until December 2025, responsible for NLRB litigation, union contract interpretation, labor arbitrations, and positive employee relations strategy. Trump nominated him to NLRB July 17, 2025. Senate HELP Committee hearing Oct 1, 2025. Committee advanced 12-11 on Dec 3. Senate confirmed Dec 18, 2025. Sworn in Jan 7, 2026, term expires Dec 16, 2029. Prior career: Morgan Lewis & Bockius (management-side labor firm), Blank Rome LLP, Aramark, IHG, MGM Resorts International. Education: Villanova Law, Cornell ILR.
SENATE HEARING CONFLICT: At his Oct 1, 2025 HELP Committee hearing, Mayer was grilled by both Sen. Sanders (I-VT) and Sen. Hawley (R-MO) about Boeing's ongoing IAM 837 strike in St. Louis (Hawley's state). Mayer testified he was 'not involved in the negotiations' and 'not serving as a representative to the company at the hearing,' declining to comment on strike discussions or executive compensation. Yet NLRB docket records show Mayer was listed as Boeing's legal representative in NLRB Case 19-CA-352164 filed just 12 months earlier. The committee advanced him 12-11 on Dec 3 after months of delay, with the initial vote struck by the committee. Hawley's opposition to Mayer — a Trump nominee — from the right is notable: a Republican senator questioning a Republican nominee's ties to a corporation fighting workers in his state.