Universal Camera Corp. v. NLRB 340 U.S. 474 (1951)
Universal fired an
employee for filing a grievance against the company and testifying in a National
Labor Relations Act (NLRA) proceeding.
that the employee was fired for punching his boss, and it had nothing to
do with the grievance.
Administrative Proceeding, the National Labor Relations Board (NLRB)
ordered Universal to rehire the employee and pay him lost wages.
NLRB made this
ruling even though their own Administrative Law Judge agreed with
Universal and recommended that the charges be dismissed.
Court affirmed. Universal appealed.
Court found that NLRB's findings of fact were "supported by substantial
evidence on the record considered as
a whole" within the meaning of NLRA §10(e).
Court only looked at evidence that supported the Agency's position, and
did not consider the report of the NLRB's examiner when making their
Court found that they could only reverse the NLRB's decision if it was clearly
The US Supreme
The US Supreme
Court found that courts should defer to a Federal Agency's findings of
fact if supported by "substantial evidence on the record considered as a whole."
Procedures Act §706(2)(e) says that
substantial evidence is the standard of review for
evidence is not necessarily a preponderance
of evidence. It is evidence that
would "appeal to a reasonable mind."
evidence does not mean that a court would reach the same
decision. The Agency is permitted to go with a minority view, as long
as it is reasonable to someone who has heard both sides.
is a decision that is not 'off the wall', but something that someone
could believe in.
should keep a good record of their decision-making process.
The Court found
that courts have the ability to set aside an Administrative Agency's
decision if they do not find that the evidence supporting the decision is
substantial, when viewed in light
of all the evidence in the record.
That means you
have to look at the evidence that supports the Agency as well as
evidence that goes against the Agency.
In this case,
the Court found that when they looked at the evidence as a whole, the
NLRB's decision did not support the evidence. Therefore they overturned
analogized the job of the court in reviewing an Agency decision to that
of an Appellate Court reviewing the decision of a special master.
This case was one
of the first cases to come to the Supreme Court after the passage of the Administrative