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NLRB v. Jones & Laughlin Steel Corp

Citation. 301 U.S. 1, 57 S. Ct. 615, 81 L. Ed. 893, 1937 U.S. 1122.
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Brief Fact Summary.

The National Labor Relations Act (the Act) establishes a comprehensive labor/management regulatory scheme. The Plaintiff, the National Labor Relations Board (Plaintiff), brought charges against the Defendant, Jones & Laughlin (Defendant), for firing an employee in violation the Act.

Synopsis of Rule of Law.

Acts, whether direct or indirect, that burden or obstruct interstate commerce are within the reach of Congress’ power under the Commerce Clause.


The Act sets forth a comprehensive scheme for regulating management/labor relations. Among the Act’s provisions are the rights of laborers to organize and collective bargain. Defendant fired an employee for attempting to organize a union. Thereupon, the Plaintiff brought charges against Defendant for violating the Act.


Did the labor/management relations scheme of the Act go beyond Congress’ power to legislate under the Commerce Clause?


No. The lower court is reversed.
Acts having an effect on interstate commerce cannot be immune from federal regulation just because they derive from labor disputes. It is the effect on interstate commerce, not the source of the effect that determines Congress’ power to legislate. Whether or not a particular act affects commerce in a way sufficient to come under federal control must be determined on a case-by-case basis.
Moreover, the statute is relatively unobtrusive. It does nothing more than safeguard a fundamental right. Employees have a clear right to organize and select their representatives for lawful purposes.


The court abandons the direct and indirect approach used in earlier cases.

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