NLRB v. Jones & Laughlin Steel Corp.
301 U.S. 1 (1937)
Jones & Laughlin was the
nation's largest steel producer. They were charged with violating a
Federal Statute prohibiting discrimination against workers who wanted to
join a labor union.
The company had fired
several employees at its plant in Aliquippa, Pennsylvania after they
moved to unionize.
The NLRB ruled against the
company but Jones refused to comply on the grounds that they believed the
act was unconstitutional.
Since the factory in
question was a steel manufacturing plant, this case is similar to Carter
v. Carter Coal Co. (298 U.S. 238
Jones argued that the
Federal government did not have the authority to enact the Statute
because it lacked the power to regulate completely intrastate business
(under the Interstate Commerce Clause).
The Trial Court overturned the
NLRB's decision. NLRB appealed.
The US Supreme Court reversed.
The US Supreme Court found
that there is a Federal interest in allowing workers to unionize.
The Court found that since
Jones wasn't just a steel mill (they owned mines and shipping and other
things), and their aggregate company did traffic in interstate commerce.
Therefore, this case was distinguished from Carter.
In a dissent, it was argued
that he Court was enhancing Congress' power under the Interstate
Commerce Clause. The dissent felt that
the Congress could regulate via the Interstate Commerce Clause, but that Congress' interference should be
limited to cases where a violation is "direct and material".