In Jolliff, we canvassed the tests and approaches of other circuits and created a framework for ascertaining whether a defamatory meaning can be gleaned from the allegedly defamatory statement.
Concluding that "when the entire record is considered there was substantial evidence to support the Board's finding that [employee's] discharge was the result of his having presented a grievance to the management" even though employee was overheard referring to company's superintendent as "the horse's ass" and was thereafter summarily discharged
Holding that the critical inquiry in determining whether action by a single employee constitutes concerted activity is whether such action is in furtherance of a group concern
In Mushroom Transportation Co. v. NLRB, 330 F.2d 683, 685 (3d Cir. 1964), we held that to qualify as concerted activity "it must appear at the very least that [the conduct] was engaged in with the object of initiating or inducing or preparing for group action or that it had some relation to group action in the interest of the employees."