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 (1936)).
    • 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”.