NLRB v. Jones and Laughlin Steel Corp. Case Brief

Summary of NLRB v. Jones & Laughlin Steel Corp.
301 U.S. 1 (1937)

Facts: ? operated a national level iron and steel plant. ? was accused of discriminatory discharges of its employees for their involvement in union activities. The Labor Board concluded that the National Labor Relations Act was applicable to the current case and ? violated NLRA by discharging its employees.

Procedure: Court of Appeals denied the Board’s petition on the ground that the order lay beyond the range of federal power.

Issue: Did the commerce clause of the Constitution give Congress the power to enforce NLRA on the ??

Holding: Yes

Rationale: The Board under NLRA is only empowered to act when the discriminatory discharges burden or obstruct commerce. According to the court: “It is a familiar principle that acts which directly burden or obstruct interstate or foreign commerce, or its free flow, are within the reach of the congressional power." Although some activities might seem intrastate individually, but they might have such a close and substantial relation to interstate commerce that their control is essential and appropriate to protect the commerce from burdens and obstructions. The fact that the employees here were involved in production is not the end of the matter. Their discharge would have immediate and catastrophic effects on interstate commerce. According to the court, “When industries organize themselves on a national scale, making their relation to interstate commerce the dominant factor in their activities, how can it be maintained that their industrial labor relations constitute a forbidden field into which Congress may not enter…" Reversed.

Dissent: The effect of the discharge of employees is too remote and indirect to fall under the Commerce Clause. Only 10 out of 10,000 employees were discharged.

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