In NLRB v. City Disposal Systems, 465 U.S. 822, 104 S.Ct. 1505, 79 L.Ed.2d 839 (1984) a truck driver was discharged when he refused to drive a vehicle that he reasonably believed to be unsafe because of faulty brakes. The employee in City Disposal, James Brown, was covered by a collective bargaining agreement which permitted him to refuse to drive an unsafe vehicle unless the refusal was unjustified. The Board held Brown's conduct protected under the Interboro doctrine. The Sixth Circuit, following the prevailing view in the courts of appeals, denied enforcement on the ground that Interboro was inconsistent with a literal reading of "concerted activities." Reversing the Sixth Circuit, the Supreme Court made clear that section 7 does not compel a narrowly literal interpretation of "concerted activities," but rather is to be construed by the Board in light of its expertise in labor relations. While agreeing with the Meyers Board that the term "concerted activity" "clearly enough embraces the activities of employees who have joined together in order to achieve common goals," the Court emphasized that "what is not self-evident from the language of the Act ... is the precise manner in which particular actions of an individual employee must be linked to the actions of fellow employees in order to permit it to be said that the individual is engaged in concerted activity." The Court continued: Although one could interpret the phrase, "to engage in concerted activities," to refer to a situation in which two or more employees are working together at the same time and the same place toward a common goal, the language of Sec. 7 does not confine itself to such a narrow meaning. In fact, Sec. 7 itself defines both joining and assisting labor organizations--activities in which a single employee can engage--as concerted activities. Indeed, even the courts that have rejected the Interboro doctrine recognize the possibility that an individual employee may be engaged in concerted activity when he acts alone. Because the Court found that the meaning of "concerted activities" was subject to varying interpretations based on "differing views regarding the nature of the relationship that must exist between the action of the individual employee and the actions of the group in order for Sec. 7 to apply," it held that the question was for the Board to resolve in light of its expertise in labor relations, as long as its judgment was reasonable. The Court concluded that the Interboro doctrine embodied a reasonable view, agreeing with the Board that "the invocation of a right rooted in a collective bargaining agreement is unquestionably an integral part of the process that gave rise to the agreement," a process that extends from the organization of a union to the enforcement of a collective bargaining agreement achieved through group action. The Court also found that the Interboro doctrine was not inconsistent with the congressional intent in enacting section 7. Reviewing the history of that provision, the Court concluded that Congress, in enacting section 7, had "sought generally to equalize the bargaining power of the employee with that of his employer by allowing employees to band together in confronting an employer regarding the terms and conditions of their employment." Most importantly, the Court observed that "there is no indication that Congress intended to limit this protection to situations in which an employee's activity and that of his fellow employees combine with one another in any particular way." In NLRB v. City Disposal Systems, Inc., 465 U.S. 822, 104 S.Ct. 1505, 79 L.Ed.2d 839 (1984), the Supreme Court reasoned that there could be a violation of section 8(a)(1)1 of the NLRA, which protects an employee from interference with his rights under section 7, where a company fired an employee whose actions were so related to other employees' concerted activities that the firing would interfere with or restrain those other concerted activities. City Disposal, 465 U.S. at 833 n. 10, 104 S.Ct. at 1512 n. 10. In City Disposal, the Court upheld the Interboro doctrine, in which the Board finds an employee's activities concerted where the employee asserts rights under a collective bargaining agreement whether on his own or in actual concert with others. City Disposal, 465 U.S. at 830-32, 104 S.Ct. at 1510-11. The rationale for the Court's decision was that "when an employee invokes a right grounded in the collective-bargaining agreement, he does not stand alone." Id. at 832, 104 S.Ct. at 1511. The Supreme Court simply recognized that a worker's actions are concerted when tied to the actions of his fellow employees, and in City Disposal, the collective bargaining agreement itself provided the bond between one worker and another. Id. at 830-37, 104 S.Ct. at 1510-14.