ABSTRACT Procedural justice pertains to fairness judgments based on norms of social process involving acceptable behavior and allowance for proper treatment of people (Lind & Tyler, 1988). Research has clearly documented that people perceive procedures are fair when they are given the opportunity to voice their opinions and preferences. While studies clearly support positive effects of voice, there is a gap in the literature regarding negative voice effects. Sham, a negative voice effect, is a procedure that appears to provide the opportunity for voice prior to a decision, but the voice preferences and values are never really considered. Although defined, there was little to no research that shed light on sham and in fact, scholars generally dismissed the notion that organizational decision makers would engage in such a practice. Recent research has established the existence of sham in an organizational context (Potter, in press) and found that perceptions of sham occur prior to the announcement of the decision. This paper discusses how differences in research contexts may have contributed to prior assumptions that sham rarely occurs in organizations. These differences will be discussed by following the Leventhal (1980) framework that outlines six justice rules for determining procedural fairness. Original studies of procedural justice were conducted in courtroom settings that grounded findings in a legal context. Due to the popularity of justice research, the focus shifted from the legal arena to organizations. This paper makes new contributions to the literature by examining decision makers and contrasting the legal and organizational research contexts in order to increase understanding of organizational justice, voice effects and sham.