NLRB v. Jones & Laughlin Steel Corp.

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National Labor Relations Board v. Jones & Laughlin Steel Corporation
Seal of the United States Supreme Court.svg
Argued February 10–11, 1937
Decided April 12, 1937
Full case name National Labor Relations Board v. Jones & Laughlin Steel Corporation
Citations 301 U.S. 1 (more)
57 S. Ct. 615; 81 L. Ed. 893; 1937 U.S. LEXIS 1122; 1 Lab. Cas. (CCH) P17,017; 1 Empl. Prac. December (CCH) P9601; 108 A.L.R. 1352; 1 L.R.R.M. 703
Prior history Jones & Laughlin Steel Corp., 1 NLRB 503, enforcement denied by NLRB v. Jones & Laughlin Steel Corp., 83 F.2d 998 (5th Cir.), cert. granted, 299 U.S. 534 (1936)
Subsequent history None
Congress had the power, under the Commerce Clause, to regulate labor relations.
Court membership
Case opinions
Majority Hughes, joined by Brandeis, Stone, Roberts, Cardozo
Dissent McReynolds, joined by Van Devanter, Sutherland, Butler
Laws applied
U.S. Const. art. I, § 8, cl. 3 (the Commerce Clause); U.S. Const. amend. V (the Due Process Clause); National Labor Relations Act of 1935, 29 U.S.C. § 151 et seq.

National Labor Relations Board v. Jones & Laughlin Steel Corporation, 301 U.S. 1 (1937)[1], was a United States Supreme Court case that declared that the National Labor Relations Act of 1935 (commonly known as the Wagner Act) was constitutional. It effectively spelled the end to the Court's striking down of New Deal economic legislation, and greatly increased Congress's power under the Commerce Clause.


Jones & Laughlin Steel was America's ninth largest steel producer and the charges brought against it were that the company discriminated against workers who wanted to join the Steel Workers Organizing Committee (SWOC).[1] The company had fired ten employees at its plant in Aliquippa, Pennsylvania 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, lower courts agreed.

Opinion of the Court

Chief Justice Charles Evans Hughes 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."


Justice McReynolds questioned Congress's enhanced power under the commerce clause. Although he did not dispute Congress's regulation of interstate commerce between the states, 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.

See also


  1. Pennsylvania Historical and Museum Commission (2000-04-08). "NLRB v. Jones and Laughlin Supreme Court Ruling Historical Marker". WITF. Retrieved 2013-06-21.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>

Further reading

  • Tushnet, Mark (2008). I dissent: Great Opposing Opinions in Landmark Supreme Court Cases. Boston: Beacon Press. pp. 101&ndash, 112. ISBN 978-0-8070-0036-6.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>

External links