In Brockton Hospital, the hospital employer maintained a confidentiality policy providing that "[i]nformation concerning patients, [nurses], or hospital operations should not be discussed..., except strictly in connection with hospital business."
In NLRB v. Selwyn Shoe Manufacturing Corp., 428 F.2d 217 (8th Cir. 1970), the court's holding was that there was not substantial evidence to support the Board's findings of §§ 8(a)(3) and (1) violations.