the Board “respectfully ask[ed] that HCEA and its representatives refrain from continuing such negative or coercive comments” and alerted HCEA that “[e]ontinued such coercion ... will either result in an official request for a retraction of such statements or in clarification/correction of these statements by the district.” Thus, the letter did not forbid the allegedly intimidating comments, nor did it threaten any negative' consequences beyond its own protected expression for a failure to cease such comments. In sum, none of the letter’s statements hindered employees’ association with HCEA, prevented employees from soliciting others to join HCEA, or discouraged HCEA from advocating on behalf of its members. Cf. Thomas v. Collins, 323 U.S. 516, 535-38, 65 S.Ct. 315, 89 L.Ed. 430 (1945) (<HOLDING>); Columbus Educ. Ass’n v. Columbus City Sch.
holding union members state law claims for defamation against union preempted recognizing that union members interests are adequately represented by the union holding that labor union membership fell outside commerce holding that a union officials comments may be used to infer the object of union activity holding that a law forbidding solicitation of union membership without obtaining an organizers card infringed on the right of speech and assembly to inform people of the advantages of union membership and persuade them to join a specific union