301 U.S. 1 (1937)
In 1935 the Beaver Valley Lodge No. 200, affiliated with the Amalgamated Association of Iron, Steel and Tin Workers of America, filed a verified charge with the National Labor Relations Board alleging that the Jones & Laughlin Steel Corporation had engaged in unfair labor practices by discriminating against union members with regard to hire and tenure of employment and by coercing and intimidating employees to interfere with their self-organization.1
The Board issued a complaint against the corporation, which appeared specially to contest jurisdiction, admitted the discharges, and asserted they were made for inefficiency, rule violations, or other good reasons unrelated to union membership.2 After the Board denied the corporation’s motion to dismiss for lack of jurisdiction, the corporation withdrew from further participation.3
The Board then received evidence on the merits and issued findings and an order directing the corporation to cease discrimination, reinstate ten named employees, make good their lost pay, and post notices of non-discrimination for thirty days.4 The Board petitioned the Circuit Court of Appeals for the Fifth Circuit to enforce the order, but that court denied the petition, holding the order lay beyond federal power, after which the Supreme Court granted certiorari.5
The Jones & Laughlin Steel Corporation is organized under Pennsylvania law with its principal office in Pittsburgh and operates manufacturing plants in Pittsburgh and Aliquippa, Pennsylvania, where it produces a diversified line of steel and pig iron as the fourth largest steel producer in the United States.6 The corporation maintains a completely integrated enterprise owning and operating ore, coal and limestone properties, lake and river transportation facilities and terminal railroads.7 It owns or controls mines in Michigan and Minnesota, operates four ore steamships on the Great Lakes, owns coal mines in Pennsylvania, operates towboats and steam barges, owns limestone properties in Pennsylvania and West Virginia, and owns interconnecting railroads.8 Approximately 75 per cent. of its product is shipped out of Pennsylvania.9
The ten employees whose reinstatement was ordered included motor inspectors, a tractor driver, crane operators, a washer in the coke plant, and laborers, several of whom served as officers or group leaders in the union.10 The Board found they were discharged because of union activity.11
Whether the National Labor Relations Act of 1935 is in reality a regulation of labor relations and not of interstate commerce?12
The National Labor Relations Act empowers the Board to prevent unfair labor practices affecting commerce, where affecting commerce means burdening or obstructing commerce or the free flow of commerce.13 Congress possesses plenary power under the Commerce Clause to enact all appropriate legislation for the protection and advancement of interstate commerce.14 This power includes regulation of intrastate activities that bear a close and substantial relation to interstate commerce so that control is essential to protect that commerce from burdens and obstructions.15
No. The Act targets only those labor practices that affect commerce as defined and does not attempt to regulate all industrial labor relations.16 The Jones & Laughlin Steel Corporation maintains an integrated enterprise that draws raw materials across state lines through its own transportation facilities and ships approximately seventy-five percent of its finished products out of Pennsylvania.17 A labor dispute interrupting operations at the Aliquippa plant would directly burden the free flow of commerce.18
The National Labor Relations Act of 1935 constitutes a valid regulation of interstate commerce rather than an attempt to regulate labor relations as such.19
Whether the Act can have application to the respondent’s relations with its production employees because they are not subject to regulation by the federal government?20
Although manufacturing in itself is not commerce, intrastate activities that have such a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens and obstructions fall within federal power.21 The question is one of degree.22 Congress may address recurring practices likely to obstruct or burden interstate commerce even when those practices occur in production.23
No. The fact that the ten employees were engaged in production at the Aliquippa plant does not place their relations with the employer beyond federal reach.24 The stoppage of operations at that plant by industrial strife would have an immediate and potentially catastrophic effect on the movement of raw materials into the plant and finished steel products out of Pennsylvania through the corporation’s integrated transportation network.25
The National Labor Relations Act applies to the respondent’s relations with its production employees.26
Whether the provisions of the Act violate § 2 of Article III and the Fifth and Seventh Amendments of the Constitution?27
The procedural provisions of the Act require complaint, notice, hearing, findings supported by evidence, and judicial review of all questions of jurisdiction, regularity, constitutional right, and statutory authority, thereby satisfying due process and Article III.28 Reinstatement and back-pay orders are statutory remedies for violation of the Act and do not constitute suits at common law requiring a jury trial under the Seventh Amendment.29
No. The corporation received notice and an opportunity to be heard on both jurisdiction and the merits yet withdrew after the jurisdictional ruling.30 The Board’s findings rest on evidence, and the remedies of reinstatement with back pay are appropriate sanctions for the statutory violation rather than common-law damages.31
The provisions of the National Labor Relations Act do not violate Article III or the Fifth and Seventh Amendments.32