Holding that absent a statute attorney fees are normally unavailable unless "the taxation of such costs is essential to the doing of justice . . . in exceptional cases"
In N.L.R.B. v. Tommy's Spanish Foods, Inc., 463 F.2d 116 (9th Cir. 1972), the employer met with the employees to inform them "[we] would never agree to any union demand to which `we were opposed as a matter of principle.'"
Holding that § 8(c) protected an employer's speech, undertaken to “correct any misunderstandings,” informing employees that their signed union cards were not confidential and that the employer retained the right to discharge or discipline employees for cause