NLRB v. Hearst Publications
|NLRB v. Hearst Publications|
|Argued February 8–9, 1944
Decided April 24, 1944
|Full case name||National Labor Relations Board v. Hearst Publications, Inc|
|Citations||322 U.S. 111 (more)
64 S. Ct. 851; 88 L. Ed. 1170; 1944 U.S. LEXIS 1201; 8 Lab. Cas. (CCH) P51,179; 14 L.R.R.M. 614
|Prior history||Court of Appeals refused to enforce the NLRB's orders, 136 F.2d 608 (reversed).|
|Reviewing courts have limited review over administrative agencies' interpretation of terms in their organic statutes. The NLRB's finding that the newsboys were employees was subject to deference.|
|Majority||Rutledge, joined by Stone, Black, Frankfurter, Douglas, Murphy, Jackson|
|National Labor Relations Act|
NLRB v. Hearst Publications, 322 U.S. 111 (1944) was an administrative law case heard before the United States Supreme Court. The case concerned the meaning of the term "employees" in the National Labor Relations Act (NLRA).
Hearst Publications (Hearst), the publishers of four daily Los Angeles newspapers, refused to bargain collectively with their newsboys. The newsboys filed petitions with the National Labor Relations Board (NLRB) for certification as a local union. The NLRB found that the newsboys were full-time employees within the meaning of the NLRA and ordered Hearst bargain with the newsboys. The United States Court of Appeals for the Ninth Circuit refused to enforce the order, reasoning that the newsboys were independent contractors, rather than employees.
Decision of the Court
Justice Rutledge, delivering the opinion of the court, ruled that the NLRB's interpretation of the Act was not erroneous. The court held that when an administrative agency engages in "specific application of a broad statutory term in a proceeding in which the agency administering the statute must determine it initially, the reviewing court's function is limited." The newsboys were employees within the meaning of the Act, with whom Hearst was required to collectively bargain.
Justice Roberts, dissenting, wrote that "the question of who is an employee, so as to make the statute applicable to him, is a question of the meaning of the Act and, therefore, is a judicial and not an administrative question."
- NLRB v. Hearst Publications, 322 U.S. 111, 113-15 (1944)
- Id. at 131.
- Id. at 136.
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