NLRB v. Jones & Laughlin Steel Corp.
1937 U.S. Supreme Court case upholding the National Labor Relations Act as constitutional / From Wikipedia, the free encyclopedia
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National Labor Relations Board v Jones & Laughlin Steel Corporation, 301 U.S. 1 (1937), was a United States Supreme Court case that upheld the constitutionality of the National Labor Relations Act of 1935, also known as the Wagner Act. The case represented a major expansion in the Court's interpretation of Congress's power under the Commerce Clause and effectively spelled the end to the Court's striking down of New Deal economic legislation.
National Labor Relations Board v. Jones & Laughlin Steel Corporation | |
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Argued February 10–11, 1937 Decided April 12, 1937 | |
Full case name | National Labor Relations Board v. Jones & Laughlin Steel Corporation |
Citations | 301 U.S. 1 (more) 57 S. Ct. 615; 81 L. Ed. 893; 1937 U.S. LEXIS 1122; 1 Lab. Cas. (CCH) ¶ 17,017; 1 Empl. Prac. December (CCH) ¶ 9601; 108 A.L.R. 1352; 1 L.R.R.M. 703 |
Case history | |
Prior | Jones & Laughlin Steel Corp., 1 NLRB 503, enforcement denied by NLRB v. Jones & Laughlin Steel Corp., 83 F.2d 998 (5th Cir. 1936), cert. granted, 299 U.S. 534 (1936) |
Subsequent | None |
Holding | |
Congress had the power, under the Commerce Clause, to regulate labor relations. The National Labor Relations Act only applied to industries that impacted interstate commerce (either directly or indirectly) and that was sufficient for the act to stand. Even purely intrastate disputes between management and labor would fall under the jurisdiction of the act, as a negative relation between the two could negatively impact interstate commerce. | |
Court membership | |
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Case opinions | |
Majority | Hughes, joined by Brandeis, Stone, Roberts, Cardozo |
Dissent | McReynolds, joined by Van Devanter, Sutherland, Butler |
Laws applied | |
U.S. Const. art. I, § 8, cl. 3 (the Commerce Clause); U.S. Const. amend. V (the Due Process Clause); National Labor Relations Act of 1935, 29 U.S.C. § 151 et seq. |
The case arose after the National Labor Relations Board (NLRB) ordered Jones & Laughlin Steel to rehire workers who had been fired for seeking to unionize. Jones and Laughlin refused to comply on the grounds that the Wagner Act, which had established the NLRB, was unconstitutional.
In a 5–4 decision, Chief Justice Charles Evans Hughes upheld the constitutionality of the Wagner Act, holding that Congress could regulate economic activities that were "intrastate in character when separately considered" if they held "such a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens and obstructions." In his dissent, Associate Justice James Clark McReynolds argued that Congress's power to regulate interstate commerce should be limited to cases in which a violation is "direct and material."