National Labor Relations Board v. Jones & Laughlin Steel Corporation
Encyclopedia
National Labor Relations Board v. Jones & Laughlin Steel Corporation, 301 U.S. 1
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

  (1937), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

  case that declared that the National Labor Relations Act
National Labor Relations Act
The National Labor Relations Act or Wagner Act , is a 1935 United States federal law that limits the means with which employers may react to workers in the private sector who create labor unions , engage in collective bargaining, and take part in strikes and other forms of concerted activity in...

  of 1935 (commonly known as the Wagner Act) was constitutional. It effectively spelled the end to the Court's striking down of New Deal
New Deal
The New Deal was a series of economic programs implemented in the United States between 1933 and 1936. They were passed by the U.S. Congress during the first term of President Franklin D. Roosevelt. The programs were Roosevelt's responses to the Great Depression, and focused on what historians call...

 economic legislation, and greatly increased Congress's
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....

 power under the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...

.

Facts

Jones & Laughlin Steel  was America
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...

's fourth largest steel producer and the charges brought against it were that the company discriminated against workers who wanted to join a labor union
Trade union
A trade union, trades union or labor union is an organization of workers that have banded together to achieve common goals such as better working conditions. The trade union, through its leadership, bargains with the employer on behalf of union members and negotiates labour contracts with...

. The company had fired ten employees at its plant in Aliquippa, Pennsylvania
Aliquippa, Pennsylvania
Aliquippa is a city in Beaver County, Pennsylvania, United States, within the Pittsburgh metropolitan area. The population was 9,438 at the 2010 census. Formerly a borough, it was formally named a city in 1987 by the Aliquippa Council.-History:...

  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
Precedent
In common law legal systems, a precedent or authority is a principle or rule established in a legal case that a court or other judicial body may apply when deciding subsequent cases with similar issues or facts...

, lower courts agreed.

Opinion of the Court

Chief Justice Charles Evans Hughes
Charles Evans Hughes
Charles Evans Hughes, Sr. was an American statesman, lawyer and Republican politician from New York. He served as the 36th Governor of New York , Associate Justice of the Supreme Court of the United States , United States Secretary of State , a judge on the Court of International Justice , and...

  wrote the majority opinion in the case, which reversed the lower court's ruling in a 5-4 decision. Per Justice Hughes: "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."

Dissent

Justice McReynolds questioned Congress's enhanced power under the commerce clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...

. Although he did not dispute Congress's regulation of interstate commerce between the states
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...

, he stated that the 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 them in the Constitution.

External links

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