Stating that employer can prohibit employees from wearing buttons emblazoned with the slogan "Don't be a Scab" because of slogan's inherent tension to incite unrest and resentment; however, the restriction does not include "passive inoffensive advertisement of organizational aims and interests . . . which in no way interferes with discipline and production"
In N.L.R.B. v. McCatron, 216 F.2d 212 (9th Cir. 1954), cert. den., 1955, 348 U.S. 943, 75 S.Ct. 365, 99 L.Ed. 738, strikers acted in the good faith but mistaken belief that a fellow employee, whose reinstatement they sought, had been discharged because of union activities.
In Rawleigh, delivery and shipment of property was impeded, and nonstriking employees were unable to enter the plant for more than a month because of the "breast to back" picketing technique and were repelled by physical force if they attempted to enter.
In National Labor Relations Board v. Perfect Circle Co., 4 Cir., 162 F.2d 566, the Board ordered the reinstatement of four employees who, according to the company's contention, were discharged for having illegally barred the plant manager from the plant during a strike.