Brief Fact Summary. The National Labor Relations Board (“N.L.R.B.”) brought suit against the Defendant, Jones & Laughlin (Defendant), for engaging in unfair labor practices, specifically, the discharge of certain employees based on union affiliation.
Synopsis of Rule of Law. Congress’ power to regulate commerce is plenary, in the sense that intrastate activities that affect interstate commerce are within the purview of the commerce power.
Held. Yes. Reversed and remanded.
If intrastate activities have a “close and substantial relation to interstate commerce,” Congress has the explicit power to control them insofar as they affect interstate commerce. In particular, the Supreme Court of the United States (Supreme Court) notes that Defendant’s activities are so “far-flung” that any deleterious action in its local operations would have a direct and immediate effect on interstate commerce.
Defendant’s denial of its employees’ right to self-organize is an imminent cause of labor strife, and thus could affect interstate commerce. As such, Congress is within its powers to regulate the employees’ ability to self-organize.
Dissent. Justice James McReynolds (J. McReynolds), dissenting, argued that stare decisis required that pure manufacture be outside the powers of Congress to regulate interstate commerce.
Discussion. This case is the first in long line of cases representing an expanding commerce power for the United States Congress that continues into the 1990s. According to the majority, almost any activity that affects interstate commerce is open to Congressional regulation.