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Universal Camera Corp. v. NLRB

Law Dictionary

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Administrative Law Keyed to Strauss

Citation. Universal Camera Corp. v. NLRB, 340 U.S. 474, 71 S. Ct. 456, 95 L. Ed. 456, 1951 U.S. LEXIS 2428, 19 Lab. Cas. (CCH) P66,191, 27 L.R.R.M. 2373 (U.S. Feb. 26, 1951)

Brief Fact Summary. The Court of Appeals for the Second Circuit granted enforcement of an order directing Universal Camera Corporation (Petitioner) to reinstate an employee with back pay who was discharged because he gave testimony under the Wagner Act (Act), and cease and desist from discriminating against any employee who files charges or gives testimony under the Act. The views of that court conflicted with those of the Court of Appeals for the Sixth Circuit, and clash of opinions required settlement by the United States Supreme Court.

Synopsis of Rule of Law. The “substantial evidence test” was the standard of review under all three statutes.

Facts. The Wagner Act was one of the principle New Deal statutes, and heavily regulated the collective bargaining process and, in many cases, required employers to deal with the unions. That Taft-Hartley Act was enacted in 1947 to amend some features of the Wagner Act that were deemed to tilt the balance too far against employers. The lower courts were reaching different conclusions about the application of the Act, so settlement was required by the Supreme Court. The Petitioner claimed that the Court of Appeals erred in holding that it was barred from taking into account the report of the examiner on questions of fact insofar as that report was rejected by the board.

Issue. What was the effect of the Administrative Procedure Act and the Taft-Hartley Act on the duty of the Court of Appeals when called upon to review orders of the National Labor Relations Board (NLRB)? Was the Court of Appeals bound by the Board’s rejection of an examiner’s findings?

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