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NLRB v. Jones & Laughlin Steel Corp.

301 U.S. 1 (1937)

tl;dr: Congress may regulate labor relations because they have such a close and substantial relationship to interstate commerce.

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The case of "National Labor Relations Board v. Jones & Laughlin Steel Corp." involved the violation of the National Labor Relations Act of 1935 by Jones & Laughlin Steel Corporation. The corporation was charged with unfair labor practices, including discrimination against union members and coercion of employees to interfere with their self-organization. The National Labor Relations Board ordered the corporation to cease and desist from such practices, offer reinstatement to ten employees, make good their losses in pay, and post notices for thirty days that the corporation would not discriminate against union members. The corporation failed to comply, and the Board petitioned the Circuit Court of Appeals to enforce the order, which was denied. The Supreme Court granted certiorari.

The National Labor Relations Act aims to eliminate obstructions to the free flow of commerce resulting from the denial of employees' right to organize and refusal of employers to accept collective bargaining. The Act defines terms, creates the National Labor Relations Board, and sets forth the right of employees to self-organization and collective bargaining. The Board is empowered to prevent unfair labor practices affecting commerce and has broad powers of investigation. Interference with the Board's duties is punishable by fine and imprisonment. The Act does not interfere with the right to strike. The Act contains a separability clause.

In this case, the labor union filed a complaint against Jones & Laughlin Steel Corporation for unfair labor practices. The corporation challenged the jurisdiction of the National Labor Relations Board (NLRB) and the constitutionality of the statute. The NLRB held a hearing, made its findings and order, and the corporation withdrew from further participation. The corporation argues that the Act is not a regulation of interstate commerce, does not apply to its relations with production employees, and violates the Constitution.

The corporation is a large, integrated enterprise engaged in the manufacturing and distribution of iron and steel products, with operations in multiple locations and subsidiaries. The Labor Board found that the corporation's operations are highly integrated and affect interstate commerce, and that the Aliquippa plant alone employs about 10,000 people in a community of approximately 30,000. However, the Circuit Court of Appeals denied the Board's petition to enforce the order.

This case involves Jones & Laughlin Steel Corporation's treatment of discharged employees who were union leaders. The National Labor Relations Act is being challenged as exceeding federal power and violating the Tenth Amendment, but it can be interpreted to operate within constitutional limits. The Act's authority is limited to labor practices that affect interstate or foreign commerce, and it prohibits employers from interfering with employees' rights to self-organization, collective bargaining, and union membership. Congress has the power to regulate any activity that has a close and substantial relation to interstate commerce, even if it is intrastate in character. The federal government can regulate local activities related to productive industry if they have a close and intimate effect on interstate commerce. Congress may enter the field of industrial labor relations when necessary to protect interstate commerce from the paralyzing consequences of industrial war.

The passage discusses the importance of recognizing employees' rights to self-organization and representation for collective bargaining, as well as the provisions of the Railway Labor Act and the National Labor Relations Act. The NLRA allows employees to negotiate with their employers for better wages and working conditions, and employers must recognize their employees' right to organize. The procedural provisions of the NLRA are being challenged, but they do not violate constitutional requirements. The NLRB's findings in this case are supported by evidence and subject to review by a designated court. The NLRB can order the reinstatement of employees and payment of lost wages for union activity, without a trial by jury. The lower court's decision is overturned, and the case is sent back for more proceedings.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:In 1935, Congress passed the National Labor Relations Act (NLRA)...

Holding:The Act may be construed so as to operate within...

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NLRB v. Jones & Laughlin Steel Corp.

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