prevails. The hearing officer found that because the video was shown at Union meetings, it was clear to viewers that it was partisan propaganda, and not Board-issued material. We agree with the Board’s finding that the video did not improperly imply that the Board supported the Union. k- Union “bribery” of employees Finally, Maremont claims that the Union impermissibly “bribed” the employees with T-shirts and other benefits. The evidence in this case does not support this objection. The hearing officer found that “[t]he overwhelming majority of employees who testified at [the] hearing testified consistent with the testimony of Union officials that employees were not required to sign [the “Vote Yes’ petition] in order to receive campaign items.” See Dickinson Press, 153 F.3d at 286 (<HOLDING>). III. CONCLUSION For all of the reasons stated
holding that an employer could only distribute its proposal to union employees when the proposal was properly before the union holding that although the distribution of economic inducements generally constitutes objectionable conduct a union may distribute inexpensive campaign propaganda such as tshirts at a union meeting holding union members state law claims for defamation against union preempted recognizing that union members interests are adequately represented by the union holding that a union officials comments may be used to infer the object of union activity