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Supreme Court of the United States - 416 U.S. 267
The case involves the exclusion of "managerial employees" from the protections of the National Labor Relations Act (NLRA). The Supreme Court ruled that Congress intended to exclude all employees properly classified as "managerial" from the Act's protections. The Court of Appeals' decision was affirmed, and the NLRB must determine whether certain buyers are "managerial employees" through adjudication. The Taft-Hartley Act of 1947 limited the definition of "supervisor" and excluded certain individuals from the Act's protections. The Board reaffirmed that representatives of management cannot be deemed employees for the purposes of the Act and may not be accorded bargaining rights. This reading of the Act was consistently followed by the Board until the North Arkansas decision in 1970 and was permitted to stand when Congress amended the Act in 1959.
This legal case discusses whether "managerial" employees are excluded from the definition of "employee" under the National Labor Relations Act. The majority held that they are excluded, but the dissenting opinion argued that all employees, including managerial employees, have the right to self-organization and collective bargaining. The Court's interpretation excludes all managerial employees, which is a substantial rewrite of the statute and questionable whether such a broad exclusion is warranted. Prior to the 1947 amendments to the Act, the Board did not completely exclude managerial employees from the class of employees protected by the Act. Congress excluded supervisors entirely from the category of employees accorded bargaining rights under the Act, but did not explicitly exclude managerial employees from the Act's protection. The Court suggests using the House Managers' statement accompanying the Conference Committee Report to clarify the exclusion of "supervisors" from the Act's coverage, but the statement indicates that Congress did not intend to exclude managerial employees from the Act's coverage. There is no legislative debate indicating an authoritative intent to exclude managerial employees as a class. Board decisions had only excluded managerial employees from rank-and-file bargaining units, but there is no indication in the legislative history that Congress intended to exclude managerial employees as a class.
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