Permitting the Board to consider the employer's clear expression of opposition to the union as background in order to determine motivation for management's conduct
In N.L.R.B. v. Collins Aikman Corp., 146 F.2d 454 (4th Cir. 1944), it was held that any real surveillance by the employer over the union activities of employees, whether frankly open or carefully concealed, falls under the prohibition of the Act.