See NYT April 23 09 "Drivers May Not Join Union At FedEx Home, Court Rules" –the US D.C. Circuit overturned an NLRB decision in finding FedEx drivers to be independent contractors rather than employees and therefore without the right to join a union (Teamsters). Major difference between drivers and nurses would be that the court said drivers could sell routes and hire helpers (and so were independent) but apparently that’s rare and extremely limited. A scary decision.