National Labor Relations Board v. Jones & Laughlin Steel Corp. 1937
| Author | Daniel Brannen, Richard Hanes, Elizabeth Shaw |
| Pages | 1024-1030 |
Page 1024
Appellant: National Labor Relations Board
Appellee: Jones & Laughlin Steel Corporation
Appellant's Claim: That Congress has the constitutional authority under the Commerce Clause to pass legislation protecting the rights of organized labor.
Chief Lawyers for Appellant: U.S. Attorney General Homer S. Cummings, U.S. 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, Chief Justice Charles Evans Hughes, Owen Josephus Roberts, Harlan Fiske Stone
Justices Dissenting: Pierce Butler, James Clark McReynolds, George Sutherland, Willis Van Devanter
Date of Decision: April 12, 1937
Decision: Ruled in favor of the National Labor Relations Board by finding that Congress has authority under the Commerce Clause to regulate labor relations.
Significance: The landmark ruling signaled a radical change in the Supreme Court's acceptance of Congressional power to regulate economic matters.
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The right of workers to ban together seeking better working conditions was not traditionally recognized in U.S. history. For decades Supreme Court decisions supported a laissez-faire form of economy in which businesses operate with minimal government interference, letting the marketplace guide economic growth. The Commerce Clause in Article I, Section 8, of the Constitution did give Congress power to "regulate Commerce . . . among the several states." But the clause was typically interpreted very narrowly by the Court, restricting the power of the federal government in economic matters.
Likewise, the courts did not interfere with the freedom of an employer to contract for labor with his employee. According to the courts, employers and employees had the right to bargain free of government interference under the Due Process Clause of the Fifth Amendment. The clause states that "No person shall be . . . deprived of life, liberty, or property, without due process of law." In addition the Contract Clause in Article I reads, "No State shall . . . make any . . . Law impairing the Obligation [responsibility] of Contracts." Therefore, the Court used the Fifth's Due Process Clause to limit federal regulation of business activities and the Contract Clause to limit state regulation.
Employers were free to take a variety of actions to discourage employees from joining organizations, such as labor unions. Labor unions are groups of workers who have joined together to seek better work conditions. One of the more common means to discourage an employer from forming a labor union was known as yellow-dog contracts. Employers forced employees to sign these contracts agreeing to not join unions, or to quit unions if already a member. Employees could be fired if they did not comply with the contract. The Supreme Court ruled in Adair v. United States (1908) that yellow-dog contracts were legal under the "liberty of contract" concept.
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