NLRB v. Jones & Laughlin Steel Corp.
|National Labor Relations Board v. Jones & Laughlin Steel Corporation|
|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)|
|Prior history||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)|
|Congress had the power, under the Commerce Clause, to regulate labor relations.|
|Majority||Hughes, joined by Brandeis, Stone, Roberts, Cardozo|
|Dissent||McReynolds, joined by Van Devanter, Sutherland, Butler|
|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.|
National Labor Relations Board v. Jones & Laughlin Steel Corporation, 301 U.S. 1 (1937), was a US labor law case in the United States Supreme Court that declared that the National Labor Relations Act of 1935 (commonly known as the Wagner Act) was constitutional. It effectively spelled the end to the Court's striking down of New Deal economic legislation, and greatly increased Congress's power under the Commerce Clause.
Jones & Laughlin Steel was America's fourth largest steel producer and the charges brought against it were that the company discriminated against workers who wanted to join the Steel Workers Organizing Committee (SWOC). The company had fired ten employees at its plant in Aliquippa, Pennsylvania after they moved to unionize. The NLRB ruled against the company and ordered the workers be rehired and given back pay, but Jones & Laughlin refused to comply on the grounds that they believed the act was unconstitutional. Citing Supreme Court precedent, lower courts agreed.
Opinion of the Court
Chief Justice Charles Evans Hughes wrote the majority opinion in the case, which reversed the lower court's ruling, in a 5-4 decision: "Although activities may be intrastate in character when separately considered, if they have such a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens and obstructions, Congress cannot be denied the power to exercise that control."
Dissenting opinion of Justice McReynolds
Justice McReynolds questioned Congress's enhanced power under the commerce clause. Although he did not dispute Congress's regulation of interstate commerce between the states, he stated that Congress's interference should be in cases where a violation is "direct and material." As an example McReynolds stated that taxation on property may indirectly, but seriously, affect the cost of transportation. In conclusion, he stated that Congress had transcended the power granted to it by the Constitution.
- NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1 (1937). This article incorporates public domain material from this U.S government document.
- Pennsylvania Historical and Museum Commission (2000-04-08). "NLRB v. Jones and Laughlin Supreme Court Ruling Historical Marker". WITF. Retrieved 2013-06-21.
- NLRB v. Jones & Laughlin Steel Corp., 83 F.2d 998 (5th Cir. 1936).
- Tushnet, Mark (2008). I dissent: Great Opposing Opinions in Landmark Supreme Court Cases. Boston: Beacon Press. pp. 101–112. ISBN 978-0-8070-0036-6.