''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 ...
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
The Case Corporation was a manufacturer of agricultural machinery and construction equipment. Founded, in 1842, by Jerome Increase Case as the J. I. Case Threshing Machine Company, it operated under that name for most of a century. For ano ...
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
The Case Corporation was a manufacturer of agricultural machinery and construction equipment. Founded, in 1842, by Jerome Increase Case as the J. I. Case Threshing Machine Company, it operated under that name for most of a century. For ano ...
operated a factory in
Rock Island, Illinois
Rock Island is a city in and the county seat of Rock Island County, Illinois, United States. The original Rock Island, from which the city name is derived, is now called Arsenal Island. The population was 37,108 at the 2020 census. Located on ...
, and in 1941 the
Congress of Industrial Organizations
The Congress of Industrial Organizations (CIO) was a federation of unions that organized workers in industrial unions in the United States and Canada from 1935 to 1955. Originally created in 1935 as a committee within the American Federation of ...
(CIO) started working to organize the workers there, working to become their
union. 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 ...
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 seco ...
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 World War II by country, vast majority of the world's countries—including all of the great power ...
, 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
Racine ( ) is a city in and the county seat of Racine County, Wisconsin, United States. It is located on the shore of Lake Michigan at the mouth of the Root River. Racine is situated 22 miles (35 km) south of Milwaukee and approximately 60 ...
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'', 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 "orga ...
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