and rightly concluded that the Board’s letter fell on the non-threatening side of the line. HCEA resists this analysis with four arguments, none of which have merit. First, HCEA argues that Stewart’s statements were not protected because they did not express an opinion on the desirability of union presence or joining a union. Appellant Br. 12, 14. In rejecting a similar argument based on § 49-5-606(a)(5)’s structure, the district court correctly found that the language granting protection for empl (2d Cir.1976) (ruling that employer did not interfere with employees’ rights by advising them they could withdraw their union authorization cards and by supplying the address of the union headquarters for that purpose); J.P. Stevens & Co. v. NLRB, 449 F.2d 595, 597-98 (4th Cir.1971) (<HOLDING>); NLRB v. Robinson, 251 F.2d 689, 641 (6th
holding that  8e protected an employers speech undertaken to correct any misunderstandings informing employees that their signed union cards were not confidential and that the employer retained the right to discharge or discipline employees for cause holding that questioning of employees about number of union cards signed placing employees in a position of having to admit or deny union support and participating in antiunion petition were all unfair labor practices holding that when public employees make statements pursuant to their official duties the employees are not speaking as citizens for first amendment purposes and the constitution does not insulate their communications from employer discipline holding that threatening to discipline employees for not reporting union solicitation violated  8a1 holding that the fact that employer had knowledge of the employees protected activity was not sufficient to establish a prima facie case of retaliation where the timing of the discharge was not proximate to the protected activity