''Universal Camera Corp. v. NLRB'', 340 U.S. 474 (1951), was 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 which held that a court will defer to a federal agency's findings of fact if supported by "substantial evidence on the record considered as a whole.". ''Universal Camera'' added another qualification to the substantial evidence test laid down in '' Consolidated Edison Co. v. NLRB''. The evidence supporting the agency's conclusion must be substantial in consideration of the record as a whole, even including the evidence that is not consistent with the agency's conclusion.

Background

Universal Camera Corp. fired an employee who testified under the

Wagner Act 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

National Labor Relations Board The National Labor Relations Board (NLRB) is an independent agency of the federal government of the United States with responsibilities for enforcing U.S. labor law in relation to collective bargaining and unfair labor practices. Under the Na ...

ordered Universal Camera Corp. to reinstate the employee with back pay and to cease and desist terminating employees for this reason. The

Court of Appeals for the Second Circuit The United States Court of Appeals for the Second Circuit (in case citations, 2d Cir.) is one of the thirteen United States Courts of Appeals. Its territory comprises the states of Connecticut, New York and Vermont. The court has appellate juris ...

upheld the order, and the Supreme Court granted certiorari to resolve a

circuit split In United States federal courts, a circuit split occurs when two or more different circuit courts of appeals provide conflicting rulings on the same legal issue. The existence of a circuit split is one of the factors that the Supreme Court of t ...

Decision

Justice Frankfurter Felix Frankfurter (November 15, 1882 – February 22, 1965) was an Austrian-American jurist who served as an Associate Justice of the Supreme Court of the United States from 1939 until 1962, during which period he was a noted advocate of judi ...

delivered the opinion of the Court. The Court discussed the "substantial evidence" test established by the Court in ''Consolidated Edison Co. v. NLRB'', which interpreted the Wagner Act, the original National Labor Relations Act. The Act provided that " e findings of the Board as to the facts, if supported by evidence, shall be conclusive." The ''Con Edison'' court read "evidence" to mean "substantial evidence." "Substantial evidence is more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." The ''Universal Camera'' Court reviewed the Act's legislative history, concluding that " is fair to say that in all this Congress expressed a mood... As legislation that mood must be respected." The Court found that both the Administrative Procedure Act and the Taft-Hartley Act, which amended the National Labor Relations Act, required that courts consider the whole record. In weighing the substantiality of evidence, courts must thus consider the whole body of evidence, including views opposed to the ultimate decision. Justices

Black Black is a color which results from the absence or complete absorption of visible light. It is an achromatic color, without hue, like white and grey. It is often used symbolically or figuratively to represent darkness. Black and white ...

and

Douglas Douglas may refer to: People * Douglas (given name) * Douglas (surname) Animals * Douglas (parrot), macaw that starred as the parrot ''Rosalinda'' in Pippi Longstocking *Douglas the camel, a camel in the Confederate Army in the American Civi ...

concurred only in parts I and II of the opinion, and dissented from part III.''Universal Camera'', 340 U.S. at 497. ''Universal Camera'' has been "the leading case on the meaning of the APA's 'substantial evidence' test for review of agency factual conclusions in formal proceedings" for over sixty years. Commentators have noted that the substantial evidence test, as determined by ''Universal Camera'', is "less deferential than the jury standard but more deferential than the clearly erroneous standard of Fed. R. Civ. Proc. 52(a)."

References

External links

* {{DEFAULTSORT:Universal Camera Corp. V. Nlrb 1951 in United States case law United States Supreme Court cases United States Supreme Court cases of the Vinson Court United States administrative case law National Labor Relations Board litigation Cameras

Background

Decision

See also

References

External links