Universal Camera Corporation v. National Labor Relations Board
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| Universal Camera Corporation v. National Labor Relations Board | |
| Reference: 340 U.S. 474 (1951) | |
| Term: 1950 | |
| Important Dates | |
| Argued: November 6-7, 1950 Decided: February 26, 1951 | |
| Outcome | |
| United States Court of Appeals for the 2nd Circuit vacated and remanded | |
| Majority | |
| Frederick Vinson • Felix Frankfurter • Sherman Minton • Hugo Black • William Douglas • Tom Clark • Harold Burton • Stanley Reed • Robert H. Jackson | |
Universal Camera Corporation v. National Labor Relations Board is a case decided on February 26, 1951, by the United States Supreme Court. It involved the effect of the Administrative Procedure Act and the Taft-Hartley Act on the judicial review procedures of Court of Appeals. The Supreme Court ruled unanimously to vacate the judgment of the United States Court of Appeals for the 2nd Circuit, since that court had not used the findings of the National Labor Relations Board's trial examiner in its review of the Board's order. The Supreme Court then remanded the case to the Appeals Court for reconsideration.[1]
In brief:
The NLRB ordered Universal Camera Corporation to reinstate an employee it had fired after the employee testified under the National Labor Relations Act of 1935.[2] Universal challenged the order, which was then reviewed by the United States Court of Appeals for the 2nd Circuit, which upheld it. In the course of its review, however, the Appeals Court held that they could not consider the findings of the NLRB trial examiner because the NLRB had rejected those findings. The Supreme Court ruled unanimously that the NLRB's rejection of the findings did not preclude the Appeals Court from considering the examiner's findings, and that the court had a duty to take these findings into account, though not necessarily to accept them. [3]
Why it matters: In its majority opinion, the Supreme Court held that the Administrative Procedure Act and the Taft-Hartley Act required an Appeals Court to meet the same standard of proof in its judicial review, which the court called the substantial evidence test.
Background
| Administrative State |
|---|
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| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
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The Administrative Procedure Act of 1946 set uniform procedures for federal agencies to create and enact regulations, as well as for courts to review those actions. Section 706(2)(e) of the act established a substantial evidence standard for review of agency actions.
| “ | ...The reviewing court shall -
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The Labor Management Relations Act of 1947, commonly known as the Taft-Hartley Act, amended the National Labor Relations Act of 1935, commonly known as the Wagner Act. The updated statute contained the following provision in Section 10(e):
| “ | (e) The Board shall have power to petition any court of appeals of the United States...
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A critical fact of the case was that the NLRB rejected the findings of its own trial examiner. The Appeals Court then held that it could not take those findings into account when making its ruling (see Deference (administrative state)). The Supreme Court disagreed with this interpretation in its majority opinion and took up the case in large part to clarify this procedure.
The apparent contradiction between the ruling of the Second Circuit of Appeals in this case and the one by the Sixth Circuit Court of Appeals in Labor Board v. Pittsburgh Steamship Co. (1949) was another factor that compelled the Supreme Court to take up the case and issue formal guidance.[6]
Oral argument
Oral arguments were held on November 6 & 7, 1950. The case was decided on February 26, 1951.
Decision
The Supreme Court ruled unanimously that the Second Circuit Court of Appeals had not been barred from using the NLRB trial examiner's report in its review of the NLRB's order, vacating the judgment of that court and remanding the case to it for review in light of the new guidance.
Felix Frankfurter wrote the majority opinion and was joined by Chief Justice Frederick Vinson and Justices Sherman Minton, Tom Clark, Harold Burton, Stanley Reed, Robert H. Jackson, Hugo Black and William Douglas.
Justices Hugo Black and William Douglas concurred with Parts I and II of the majority opinion but dissented from Part III.[1]
Opinions
Opinion of the court
Writing for the court, Justice Felix Frankfurter identified the impact of the Administrative Procedure Act and Taft-Hartley Act on judicial review as the key issue in the case. Pointing to similarities in wording in the two bills, and records from their drafting processes, Frankfurter held that both bills set the same standard for the evidence required by an Appeals Court to uphold an agency action, which he called the substantial evidence test.
| “ | It would be mischievous word-playing to find that the scope of review under the Taft-Hartley Act is any different from that under the Administrative Procedure Act...And so we hold that the standard of proof specifically required of the Labor Board by the Taft-Hartley Act is the same as that to be exacted by courts reviewing every administrative action subject to the Administrative Procedure Act.[1][5] | ” |
He held that the text and spirit of the acts thus enabled reviewing courts to invalidate agency actions if the test was not met.
| “ | Congress has merely made it clear that a reviewing court is not barred from setting aside a Board decision when it cannot conscientiously find that the evidence supporting that decision is substantial, when viewed in the light that the record in its entirety furnishes, including the body of evidence opposed to the Board's view.[1][5] | ” |
Since the trial examiner's report constituted part of the whole record, the Appeals Court had a duty to at least consider his findings. The Board's rejection of those findings did not preclude the court from doing this.
| “ | We do not require that the examiner's findings be given more weight than in reason and in the light of judicial experience they deserve. The 'substantial evidence' standard is not modified in any way when the Board and its examiner disagree.[1][5] | ” |
The next key question was whether those two acts had "altered the scope of review other than to require that substantiality be determined in the light of all that the record relevantly presents."[1] Frankfurter argued that they had increased that scope.
| “ | We conclude, therefore, that the Administrative Procedure Act and the Taft-Hartley Act direct that courts must now assume more responsibility for the reasonableness and fairness of Labor Board decisions than some courts have shown in the past...The Board's findings are entitled to respect, but they must nonetheless be set aside when the record before a Court of Appeals clearly precludes the Board's decision from being justified by a fair estimate of the worth of the testimony of witnesses or its informed judgment on matters within its special competence or both.[1][5] | ” |
In light of this new direction, the Supreme Court ruled that the Court of Appeals could not satisfy the substantial evidence test and approve the Board's order without using the findings of the trial examiner, and so remanded the case for reconsideration.
| “ | We therefore remand the cause to the Court of Appeals. On reconsideration of the record it should accord the findings of the trial examiner the relevance that they reasonably command in answering the comprehensive question whether the evidence supporting the Board's order is substantial. But the court need not limit its reexamination of the case to the effect of that report on its decision. We leave it free to grant or deny enforcement as it thinks the principles expressed in this opinion dictate.[1][5] | ” |
Concurring opinions
Justices Hugo Black and William Douglas concurred with Parts I and II of the majority opinion.
Dissenting opinions
Justices Hugo Black and William Douglas dissented from Part III of the majority opinion.
Impact
The case reaffirmed the substantial evidence test as the standard for judicial review of agency actions. Justice Frankfurter explored the legislative history of both acts and argued that in both cases, Congress had expressed a desire to increase the standard of evidence used in judicial review through the use of the substantial evidence test.
| “ | The adoption in these statutes of the judicially-constructed 'substantial evidence' test was a response to pressures for stricter and more uniform practice, not a reflection of approval of all existing practices.
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He quoted the Attorney General's Committee on Administrative Procedure to clarify the relationship between federal agencies and Courts of Appeals.
| “ | 'In general, the relationship upon appeal between the hearing commissioner and the agency ought to a considerable extent to be that of trial court to appellate court. Conclusions, interpretations, law, and policy should, of course, be open to full review. On the other hand, on matters which the hearing commissioner, having heard the evidence and seen the witnesses, is best qualified to decide, the agency should be reluctant to disturb his findings unless error is clearly shown.'[1][5] | ” |
Frankfurter concluded that review of agency actions was primarily the duty of the Courts of Appeals, and that the Supreme Court should intervene only when there was an issue of higher legal significance.
| “ | Our power to review the correctness of application of the present standard ought seldom to be called into action. Whether on the record as a whole there is substantial evidence to support agency findings is a question which Congress has placed in the keeping of the Courts of Appeals. This Court will intervene only in what ought to be the rare instance when the standard appears to have been misapprehended or grossly misapplied.[1][5] | ” |
See also
- Deference (administrative state)
- Judicial review
- Administrative Procedure Act
- Separation of powers
- Rulemaking
- Supreme Court of the United States
- History of the Supreme Court
External links
- Full Text of the Case via Justia
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 FindLaw, UNIVERSAL CAMERA CORP. v. LABOR BD. accessed December 3, 2017
- ↑ 2.0 2.1 NLRB.gov, National Labor Relations Act, accessed December 3, 2017
- ↑ Justia, Universal Camera Corp. v. Labor Board, accessed December 3, 2017
- ↑ Legal Information Institute, 5 U.S. Code § 706 - Scope of review, accessed December 3, 2017
- ↑ 5.0 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Justia, Labor Board v. Pittsburgh Steamship Co., accessed December 3, 2017
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