With the National Labor Relations Act 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. In this case, the National Labor Relations Board charged the Jones & Laughlin Steel Co. with discriminating against employees who were union members.
Was the Act consistent with the Commerce Clause?
Yes. The Court held that the Act was narrowly constructed so as to regulate industrial activities which had the potential to restrict interstate commerce. The justices abandoned their claim that labor relations had only an indirect effect on commerce. Since the ability of employees to engage in collective bargaining (one activity protected by the Act) is "an essential condition of industrial peace," the national government was justified in penalizing corporations engaging in interstate commerce which "refuse to confer and negotiate" with their workers.
Decisions
Decision: 5 votes for NLRB, 4 vote(s) against Legal provision: US Const. Art 1, Section 8, Clause 3; US Const. Amend 5; National Labor Relations Act of 1935, 29 U.S.C. § 151 et seq.
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Full Opinion by Justice Charles E. Hughes
