In Bourne, we held that interrogation which does not contain express threats is not an unfair labor practice unless certain "fairly severe standards" are met showing that the very fact of interrogation was coercive.
Holding that "hallmark" violations of NLRA "include such employer misbehavior as the closing of a plant or threats of plant closure or loss of employment, the grant of benefits to employees, or the reassignment, demotion or discharge of union adherents" and lesser violations "include such employer misconduct as interrogating employees regarding their union sympathies, holding out a `carrot' of promised benefits, expressing anti-union resolve, threatening that unionization will result in decreased benefits, or suggesting that physical force might be used to exclude the union"
Rejecting argument NLRB used section 8(c) protected statements as "as some evidence of the unfair labor practices themselves" and concluding statements were used only to "place . . . other acts in context"