National Labor Relations Board v. Jones & Laughlin Steel Corp.

Facts of the case

With the National Labor Relations Act (NLRA) of 1935, Congress determined that labor-management disputes were directly related to the flow of interstate commerce and, thus, could be regulated by the national government. The National Labor Relations Board (NLRB) charged Jones & Laughlin Steel Co. the country’s fourth largest steel producer, with discriminating against employees who were union members.

Question

Was the NLRA consistent with the Commerce Clause?

Conclusion

In an opinion written by Chief Justice Charles Evans Hughes, the majority found that companies cannot discriminate against employees for exercising their fundamental right to unionize. The Court upheld the Act, reasoning that it was narrowly constructed so as to regulate industrial activities which had the potential to restrict interstate commerce. The majority stated that any significant effect (direct or indirect) on interstate commerce allows Congress to regulate an activity under the Commerce Clause. While the manufacturing process or relationships between labor and management may not have a direct impact on the flow of goods, they have an aggregate impact on commerce. In this case, the potential secession of manufacturing activity due to conflicts between management and labor could potentially impede interstate commerce. However, Hughes carefully limited the opinion to exclude situations in which an activity had such an inconsequential or remote impact on interstate commerce that it exclusively impacted local matters.

In dissent, Justice McReynolds questioned Congress's enhanced power under the Commerce Clause.

Supreme Court of the United States

301 U.S. 1, 81 L. Ed. 893, 57 S. Ct. 615, SCDB 1936-053, 1937 U.S. LEXIS 1122

No. 419

1937-04-12

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