Appellant
National Labor Relations Board
Appellee
Jones & Laughlin Steel Corporation
Appellant's Claim
That Congress has the power to pass legislation that regulates the economy byprotecting the rights of organized labor.
Chief Lawyers for Appellant
Attorney General Homer S. Cummings, Solicitor General Stanley F. Reed, and J.Warren Madden
Chief Lawyer for Appellee
Earl F. Reed
Justices for the Court
Louis D. Brandeis, Benjamin N. Cardozo, Charles Evans Hughes (writing for theCourt), Owen Josephus Roberts, Harlan Fiske Stone
Justices Dissenting
Pierce Butler, James Clark McReynolds, George Sutherland, Willis Van Devanter
Place
Washington, D.C.
Date of Decision
12 April 1937
Decision
The Supreme Court upheld the National Labor Relations Act, signaling its willingness to uphold legislation regulating the relationship between business and labor.
Significance
The National Labor Relations Act was generally regarded as the most radical of Franklin Roosevelt's New Deal proposals. In upholding it, the Supreme Courtgave a clear signal that it was abandoning its previous allegiance to the concept of freedom of contract, empowering organized labor.
The National Labor Relations Act of 1935 (NLRA) was the most daring part of President Franklin Roosevelt's attempt to combat the severe economic woes of the Great Depression with a loose collection of legislation he called the NewDeal. The New Deal, which gave Congress unprecedented control of the economy,was based on the power given Congress in Article I, section 8 of the Constitution to "regulate Commerce . . . among the several states." For decades, theSupreme Court had curtailed Congress's power under the Commerce Clause, emphasizing instead a laissez faire approach to economic matters--that is,letting the market take care of itself, free from government intervention. The cornerstone of this philosophy was freedom of contract, which the Court said was protected by the Due Process Clause of the Fifth Amendment, which saysthat "No person shall be . . . deprived of life, liberty, or property, without due process of law." Nothing would seem to be more opposed to the Court'sexalted conception of the right of employers and employees to bargain free ofgovernment interference than legislation designed to protect labor unions.
In the mid-1930s, relations between Jones & Laughlin Steel Corporation and the employees at its Aliquippa, Pennsylvania, plant were disintegrating. Alleging that Jones & Laughlin was engaging in unfair labor practices suchas discriminating against union members in hiring and firing, Local 200 of the Amalgamated Association of Iron, Steel, and Tin Workers of America filed acomplaint with the National Labor Relations Board (NLRB), the agency chargedwith enforcing the NLRA. The NLRB upheld the complaint and ordered the corporation to cease its unfair practices. When Jones & Laughlin refused to comply, the NLRB petitioned the Fifth Circuit Court of Appeals to enforce the order. The circuit court, however, claimed that the order exceeded the bounds of federal power, and declined to enforce it. The NLRB then looked to the U.S.Supreme Court.
Prior to 1937, Roosevelt and the Supreme Court had done battle over the New Deal, with the Court striking down virtually every important piece of legislation designed to alleviate the Great Depression by regulating the economy. In1937, however, Roosevelt brought about a constitutional crisis by developinga plan to "pack" the Court with enough justices of his own choosing to override what had been the majority's opposition to the New Deal. The court-packingplan ultimately failed to pass in Congress, but it did succeed in persuadingat least two members of the Court, Chief Justice Hughes and Roberts, to reorient their attitudes towards Roosevelt's program. On 12 April 1937, less thana week after Roosevelt announced his court-packing plan, the Supreme Court handed down five decisions sustaining the constitutionality of the NLRA.
Court Recognizes Collective Bargaining as a "Fundamental Right"
Chief Justice Hughes wrote the opinion for the five-member Court majority upholding the NLRA in Jones & Laughlin.
In other words, a strike could interfere with interstate commerce. To preventlabor unrest in a time of economic crisis, the Supreme Court was more than willing to support the NLRA, which imposed a duty on employers to negotiate with their workers. But Hughes's opinion went even further, recognizing workers' "fundamental right" to organize. As a result of Jones & Laughlin, the power of unions would expand to fill the void left by the death of laissez faire.
Related Cases
The New Deal
As a candidate for president, Franklin D. Roosevelt had promised "a new dealfor the American people." Following his inauguration in 1933, he introduced policies that would be called the New Deal--economic and judicial initiativesaimed at helping the nation recover from the Great Depression. During the fabled first "Hundred Days" of his administration, Roosevelt ushered through Congress more legislation than had been passed in a comparable period of time atany point in American history. Among these was the creation of the Federal Emergency Relief Administration, which distributed a half-billion dollars in federal aid to the states. It was followed by initiatives to put out-of-work Americans back to work in what Roosevelt's critics called "alphabet agencies":the CCC (Civilian Conservation Corps), the Agricultural Adjustment Administration (AAA), the Works Progress Administration (WPA), and the National Recovery Administration (NRA). A protracted battle with the Senate in 1937 over Roosevelt's attempt to load the Supreme Court with justices loyal to him effectively ended the New Deal era, though Roosevelt continued to be a popular president.
Sources
West's Encyclopedia of American Law. St. Paul, MN: West Group, 1998.
National Labor Relations Board
Appellee
Jones & Laughlin Steel Corporation
Appellant's Claim
That Congress has the power to pass legislation that regulates the economy byprotecting the rights of organized labor.
Chief Lawyers for Appellant
Attorney General Homer S. Cummings, Solicitor General Stanley F. Reed, and J.Warren Madden
Chief Lawyer for Appellee
Earl F. Reed
Justices for the Court
Louis D. Brandeis, Benjamin N. Cardozo, Charles Evans Hughes (writing for theCourt), Owen Josephus Roberts, Harlan Fiske Stone
Justices Dissenting
Pierce Butler, James Clark McReynolds, George Sutherland, Willis Van Devanter
Place
Washington, D.C.
Date of Decision
12 April 1937
Decision
The Supreme Court upheld the National Labor Relations Act, signaling its willingness to uphold legislation regulating the relationship between business and labor.
Significance
The National Labor Relations Act was generally regarded as the most radical of Franklin Roosevelt's New Deal proposals. In upholding it, the Supreme Courtgave a clear signal that it was abandoning its previous allegiance to the concept of freedom of contract, empowering organized labor.
The National Labor Relations Act of 1935 (NLRA) was the most daring part of President Franklin Roosevelt's attempt to combat the severe economic woes of the Great Depression with a loose collection of legislation he called the NewDeal. The New Deal, which gave Congress unprecedented control of the economy,was based on the power given Congress in Article I, section 8 of the Constitution to "regulate Commerce . . . among the several states." For decades, theSupreme Court had curtailed Congress's power under the Commerce Clause, emphasizing instead a laissez faire approach to economic matters--that is,letting the market take care of itself, free from government intervention. The cornerstone of this philosophy was freedom of contract, which the Court said was protected by the Due Process Clause of the Fifth Amendment, which saysthat "No person shall be . . . deprived of life, liberty, or property, without due process of law." Nothing would seem to be more opposed to the Court'sexalted conception of the right of employers and employees to bargain free ofgovernment interference than legislation designed to protect labor unions.
In the mid-1930s, relations between Jones & Laughlin Steel Corporation and the employees at its Aliquippa, Pennsylvania, plant were disintegrating. Alleging that Jones & Laughlin was engaging in unfair labor practices suchas discriminating against union members in hiring and firing, Local 200 of the Amalgamated Association of Iron, Steel, and Tin Workers of America filed acomplaint with the National Labor Relations Board (NLRB), the agency chargedwith enforcing the NLRA. The NLRB upheld the complaint and ordered the corporation to cease its unfair practices. When Jones & Laughlin refused to comply, the NLRB petitioned the Fifth Circuit Court of Appeals to enforce the order. The circuit court, however, claimed that the order exceeded the bounds of federal power, and declined to enforce it. The NLRB then looked to the U.S.Supreme Court.
Prior to 1937, Roosevelt and the Supreme Court had done battle over the New Deal, with the Court striking down virtually every important piece of legislation designed to alleviate the Great Depression by regulating the economy. In1937, however, Roosevelt brought about a constitutional crisis by developinga plan to "pack" the Court with enough justices of his own choosing to override what had been the majority's opposition to the New Deal. The court-packingplan ultimately failed to pass in Congress, but it did succeed in persuadingat least two members of the Court, Chief Justice Hughes and Roberts, to reorient their attitudes towards Roosevelt's program. On 12 April 1937, less thana week after Roosevelt announced his court-packing plan, the Supreme Court handed down five decisions sustaining the constitutionality of the NLRA.
Court Recognizes Collective Bargaining as a "Fundamental Right"
Chief Justice Hughes wrote the opinion for the five-member Court majority upholding the NLRA in Jones & Laughlin.
The congressionalauthority to protect interstate commerce from burdens and obstructions is not limited to transactions which can be deemed to be an essential part of a "flow" of interstate or foreign commerce. Burdens and obstructions may be due to injurious action springing from other sources . . . That power may be exerted to protect interstate commerce "no matter what the source of the dangers which threaten it." [Quoting Second Employers' Liability Cases(1912)]
In other words, a strike could interfere with interstate commerce. To preventlabor unrest in a time of economic crisis, the Supreme Court was more than willing to support the NLRA, which imposed a duty on employers to negotiate with their workers. But Hughes's opinion went even further, recognizing workers' "fundamental right" to organize. As a result of Jones & Laughlin, the power of unions would expand to fill the void left by the death of laissez faire.
Related Cases
- United States v. E. C. Knight, 156 U.S. 1 (1895).
- Adair v. United States, 208 U.S. 161 (1908).
- Loewe v. Lawlor, 208 U.S. 274 (1908).
- A.L.A. Schechter Poultry v. United States, 295 U.S. 495 (1935).
- Carter v. Carter Coal Co., 298 U.S. 238 (1936).
The New Deal
As a candidate for president, Franklin D. Roosevelt had promised "a new dealfor the American people." Following his inauguration in 1933, he introduced policies that would be called the New Deal--economic and judicial initiativesaimed at helping the nation recover from the Great Depression. During the fabled first "Hundred Days" of his administration, Roosevelt ushered through Congress more legislation than had been passed in a comparable period of time atany point in American history. Among these was the creation of the Federal Emergency Relief Administration, which distributed a half-billion dollars in federal aid to the states. It was followed by initiatives to put out-of-work Americans back to work in what Roosevelt's critics called "alphabet agencies":the CCC (Civilian Conservation Corps), the Agricultural Adjustment Administration (AAA), the Works Progress Administration (WPA), and the National Recovery Administration (NRA). A protracted battle with the Senate in 1937 over Roosevelt's attempt to load the Supreme Court with justices loyal to him effectively ended the New Deal era, though Roosevelt continued to be a popular president.
Sources
West's Encyclopedia of American Law. St. Paul, MN: West Group, 1998.
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