JI Case Co v NLRB
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''JI Case Co. v. National Labor Relations Board'', 321 U.S. 332 (1944),''J.I. Case Co. v. NLRB'', 321 U.S
332
(1944)
is a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case dealing with
labor law Labour laws (also known as labor laws or employment laws) are those that mediate the relationship between workers, employing entities, trade unions, and the government. Collective labour law relates to the tripartite relationship between employee, ...
. Workers at the company's factory had voted to unionize, but J.I. Case Company had refused to negotiate with the new union, and tried to enforce old contracts instead. The court upheld the NLRB's decision that they'd violated the National Labor Relations Act, but said that the NLRB had to re-word the order it had issued.


Background

J.I. Case Company operated a factory in Rock Island, Illinois, and in 1941 the Congress of Industrial Organizations (CIO) started working to organize the workers there, working to become their
union Union commonly refers to: * Trade union, an organization of workers * Union (set theory), in mathematics, a fundamental operation on sets Union may also refer to: Arts and entertainment Music * Union (band), an American rock group ** ''Un ...
. They received the proper certification from the NLRB for this, and the workers voted to join the union. However, the company refused to begin collective bargaining with the CIO. They argued that most of the workers had signed individual contracts, and these contracts were still binding. After the union complained, the NLRB said that the company was guilty of
unfair labor practice An unfair labor practice (ULP) in United States labor law refers to certain actions taken by employers or unions that violate the National Labor Relations Act of 1935 (49 Stat. 449) (also known as the NLRA and the Wagner Act after NY Senator Ro ...
s, violating the
National Labor Relations Act of 1935 The National Labor Relations Act of 1935, also known as the Wagner Act, is a foundational statute of United States labor law that guarantees the right of private sector employees to organize into trade unions, engage in collective bargaining, and ...
. The Board ordered the company to start collective bargaining on terms for a new contract, to stop telling workers that their old contracts were still legally binding, and to stop having new employees sign the old contracts. A Court of Appeals granted an order of enforcement, and the company appealed to the U.S. Supreme Court.


Opinion of the court

The court sided with the NLRB in an 8-1 vote. An existing contract would ordinarily continue to have legal force until broken—for example, by a worker quitting or being fired—but under the National Labor Relations Act, collective bargaining agreements had become something of a special case:Accordingly, the fact that there was an older contract between a company and its workers did not prevent the application of the National Labor Relations Act, which required companies to enter collective bargaining with unions. Justice Jackson distinguished this situation from one where negotiations were ongoing, but no agreement had been reached yet; then individual contracts could have effect. Having decided this, the Court still felt that the wording the NLRB had originally used for its order had been too strong. The wording might have allowed workers to sue the company and yet prohibited the company from defending itself in court; so the Supreme Court issued new wording for the order, which simply told J.I. Case Co. to stop enforcing the old contracts or interfering with collective bargaining, and to tell all workers that they wouldn't be bound by the old contract. Justice
Owen Roberts Owen Josephus Roberts (May 2, 1875 – May 17, 1955) was an Associate Justice of the United States Supreme Court from 1930 to 1945. He also led two Roberts Commissions, the first of which investigated the attack on Pearl Harbor, and the sec ...
dissented, but did not write an opinion.


Historical context

This dispute was happening not only in the middle of
World War II World War II or the Second World War, often abbreviated as WWII or WW2, was a world war that lasted from 1939 to 1945. It involved the vast majority of the world's countries—including all of the great powers—forming two opposing ...
, but also in a period of other labor troubles for JI Case Company; a strike would begin in December 1945 at their factory in Racine, Wisconsin that would last for a historically-long 440 days. For the Supreme Court, this decision came seven years after ''
West Coast Hotel Co. v. Parrish ''West Coast Hotel Co. v. Parrish'', 300 U.S. 379 (1937), was a decision by the United States Supreme Court upholding the constitutionality of state minimum wage legislation. The court's decision overturned an earlier holding in ''Adkins v. Child ...
'', a case that is generally seen as the end of the ''Lochner'' era, and the beginning of an era when the Court would uphold government regulations of business and industry more often.


See also

*
United States labor law United States labor law sets the rights and duties for employees, labor unions, and employers in the United States. Labor law's basic aim is to remedy the "inequality of bargaining power" between employees and employers, especially employers "org ...


References


External links

* * {{Caselaw source, case=''JI Case Co. v. NLRB'', {{ussc, 321, 332, 1944, el=no, openjurist=https://openjurist.org/321/us/332, justia=https://supreme.justia.com/cases/federal/us/321/332/, findlaw=https://caselaw.findlaw.com/us-supreme-court/321/332.html, cornell=https://www.law.cornell.edu/supremecourt/text/321/332, courtlistener=https://www.courtlistener.com/opinion/103945/ji-case-co-v-nlrb/, googlescholar=https://scholar.google.com/scholar_case?case=2306669411963622772, loc=https://www.loc.gov/item/usrep321332/, leagle=https://www.leagle.com/decision/1944653321us3321629, vlex=https://case-law.vlex.com/vid/case-co-v-national-889049411 United States trade union case law United States Supreme Court cases 1944 in United States case law United States Supreme Court cases of the Stone Court