EMPLOYER INTERFERENCE, RESTRAINT, COERCION; THREATS OR PROMISES – Express or Implied Threats

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Where charge alleged that the respondent offered suggestions regarding curriculum issues after “implying” there were student complaints regarding charging party’s teaching techniques, and where charge implied that such conduct was connected to a comment made to her by a union representative that she could expect “repercussions” from the school district if she pursued her grievance with a private attorney, charge failed to state prima facie case of interference; respondent’s discussion with charging party concerning the curriculum cannot objectively be found to tend to discourage charging party from exercising protected rights and unions and employers are not liable for each other’s conduct.