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National Labor Relations Board v. Jones & Laughlin Steel Corp.

Citations: 301 U.S. 1; 57 S. Ct. 615; 81 L. Ed. 893; 1937 U.S. LEXIS 1122; 108 A.L.R. 1352; 1 L.R.R.M. (BNA) 703; 1 Empl. Prac. Dec. (CCH) 9601Docket: 419

Court: Supreme Court of the United States; April 12, 1937; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The case involves the National Labor Relations Board's (NLRB) finding that Jones, Laughlin Steel Corporation engaged in unfair labor practices in violation of the National Labor Relations Act of 1935. The practices included discrimination against union members and coercion of employees, affecting commerce. The NLRB ordered the corporation to reinstate employees and compensate them, but the corporation's non-compliance led the NLRB to seek enforcement through the Circuit Court of Appeals, which was initially denied. The Supreme Court reviewed the denial, affirming the NLRB's authority to regulate labor practices impacting interstate commerce. The respondent challenged the Act's constitutionality, asserting overreach of federal power, but the Court upheld its validity, emphasizing Congress's authority under the Commerce Clause to regulate activities substantially affecting commerce. The Court reinforced the protection of employees' rights to organize and collective bargaining as essential for maintaining industrial peace and safeguarding commerce. The decision resulted in the reversal of the Circuit Court's judgment, remanding the case for enforcement of the NLRB's order, including reinstatement and back pay for affected employees.

Legal Issues Addressed

Board's Authority and Enforcement of Orders

Application: The NLRB sought enforcement of its order after the corporation's non-compliance, and the Supreme Court reviewed the Circuit Court's denial of the petition, affirming the Board's authority to prevent unfair practices.

Reasoning: When the corporation failed to comply, the NLRB sought enforcement from the Circuit Court of Appeals, which denied the petition, claiming the order exceeded federal power.

Constitutional Validity of the National Labor Relations Act

Application: The respondent challenged the Act's constitutionality, arguing it overextends federal power over industry, but the Court upheld its validity for regulating commerce-affected labor practices.

Reasoning: Respondent contests the validity of the act, arguing that it improperly attempts to regulate all industry and encroaches on states’ rights, asserting that the references to interstate and foreign commerce are merely superficial.

Right to Collective Bargaining and Employee Self-Organization

Application: The NLRA protects employees' rights to self-organization and collective bargaining, and prohibits employer interference, as part of maintaining industrial peace and commerce flow.

Reasoning: Employees are guaranteed the right to organize, form or assist labor organizations, and engage in collective activities without employer coercion, which is recognized as a fundamental right.

Scope of Congressional Authority under Commerce Clause

Application: The Court emphasized that Congress has the authority to regulate intrastate activities that substantially affect interstate commerce, justifying federal jurisdiction over the respondent's operations.

Reasoning: While intrastate activities may, on their own, be local, if they closely and substantially affect interstate commerce, Congress can regulate them to prevent obstructions.

Unfair Labor Practices under the National Labor Relations Act

Application: The National Labor Relations Board (NLRB) determined that Jones, Laughlin Steel Corporation engaged in unfair labor practices by discriminating against union members and coercing employees, which affected commerce.

Reasoning: The National Labor Relations Board (NLRB) found that Jones, Laughlin Steel Corporation violated the National Labor Relations Act of 1935 by engaging in unfair labor practices that affected commerce.