To establish that state university graduate students who work as research assistants are not considered government employees for purposes of enrolling them into a union, if their work terms do not meet an IRS "20 factor test" for employee status. This relates to a Mackinac Center lawsuit filed on behalf of graduate student research assistants (GSRAs) at the University of Michigan. See also House Bill 4003, which would more broadly prohibit “stealth unionizations,” including an ongoing one involving home heath care aides and the SEIU union.