In Verizon v. NLRB, the Circuit Court of Appeals for the District of Columbia held that the NLRB erroneously overturned an arbitration award that found that the union’s waiver of the right to picket also prohibited employees from displaying pro-union signs on the windshields of their cars parked on the employer’s property. In a two to one ruling, the Board overturned the arbitrator’s decision and found that the Union’s waiver did not preclude the employees from such a display.  The Court cited the Board’s Spielberg-Olin standard of deferral, stating that the Board should defer to an arbitration award unless the award is “clearly repugnant” to the National Labor Relations Act (See, Olin Corp., 268 N.L.R.B. 573, 574 (1984); Spielberg Manufacturing Co., 112 N.L.R.B. 1080, 1082 (1955)). Thus, the Court upheld the Administrative Law Judge’s finding that the arbitration decision was not, in fact, clearly repugnant to the Act and denied the Board’s cross-application for enforcement of its findings.