NLRB v. Jones & Laughlin Steel
301 U.S. 1 (1937)
Constitutional Topic Areas:
Article I §10 Clause 3 ‘Commerce Clause’, 5th Amendment ‘Due Process Clause’, Appellate Jurisdiction
Case Facts:
As a part of FDR’s New Deal program, Congress passed the Wagner Act of 1935 establishing the National Labor Relations Board to protect worker’s rights to organize and unionize. Congress delegated authority to the board to adjudicate complaints and issue corrections if wrongdoing was found. In the following years, Jones fired a number of employees for being active union leaders. The union which they were affiliated with contacted the NLRB which conducted an investigation and filed a complaint against Jones for firing the employees for unionizing, however Jones argued the reason the employees were fired was because they were just bad at their jobs. The NRLB ordered Jones to rehire employees and pay lost wages, but when Jones refused, the NRLB petitioned the 5th circuit court to enforce their decision, but the court ruled labor disputes were to be governed by state law. The NRLB petitioned the Supreme Court with a writ of certiorari for appeal.
Questions:
1. Does Congress have the constitutional authority to allow workers to unionize and create an enforcement agency?
Holding:
1. Yes
Legal Reasoning: Chief Justice C.E. Hughes (5-4)
1. Under the Constitution’s Article I §10 Clause 3, Congress has the enumerated power to regulate anything that may have any effect on interstate commerce.
2. The federal creation of the NRLB does not encroach state’s powers because the NRLB has the power to stop unfair abuses of power that directly affect interstate commerce.
3. The NRLB’s authority to protect workers’ right to unionize is fundamental within the Constitution
Dissent: Justice J.C. McReynolds
1. If Congress can regulate anything which may have an affect on interstate commerce, Congress can effectively regulate anything it wants. The Wagner Act violates the 10th Amendment afforded state powers to regulate internal affairs. Additionally, the right to contract is violated by the Wagner Act
Significance:
With this case begins a new trend of Supreme Court imposed expansionism on Congress’ commerce clause abilities and with it comes a new era of nationalism
Reflection:
Future cases to come within the next several years including US v. Darby and Wickard v. Filburn will build upon this new era of nationalism, further strengthening Congress’ power, specifically within the realm of the commerce clause. Overall, NLRB v. Jones strengthened the power of the federal government
Supreme Court Case Briefs 