National Labor Relations Board v. Jones & Laughlin Steel Corporation
National Labor Relations Board v. Jones & Laughlin Steel Corporation
The single biggest expansion of government programs in United States history occurred with the New Deal, which was a series of laws passed by Congress and Franklin Delano Roosevelt in the 1930s. However, substantial court opposition made it very difficult for FDR to enact these policies initially. The Court ruled against many early attempts at enacting New Deal legislation, ruling that the legislation exceeded the powers afforded to Congress under the Commerce Clause of the United States Constitution. National Labor Relations Board v. Jones & Laughlin Steel Corporation was one of the cases that turned the tide for the New Deal and made subsequent sweeping jobs legislation possible.
The National Labor Relations Act
National Labor Relations Board v. Jones & Laughlin Steel Corporation was a case that related to whether the newly enacted National Labor Relations Act (NLRA) was constitutional under the Commerce Clause. The Commerce Clause says that Congress may only regulate interstate commerce, rather than regulating things that occur only within one state.
The NLRA was the first comprehensive labor law in the United States that made explicit the right to collective bargaining among employees. The NLRA allowed workers to have strikes, which was a major development, because strikes had been broken up for 50 years—often by police who hurt or even killed striking workers.
Obviously, businesses did not like this law, and a lawsuit began almost immediately. The National Labor Relations Board v. Jones & Laughlin Steel Corporation lawsuit alleged that when a place of business was in just one state, there was no interstate commerce occurring, and that Congress therefore had no authority to create regulations for these types of workplaces.
“The Switch In Time”
If National Labor Relations Board v. Jones & Laughlin Steel Corporation had been decided just a year earlier, it's very likely that it would have led to a different result. As it was, the Court ruled that the NLRA was in fact constitutional, and expanded the Interstate Commerce Clause to include actions that had an indirect influence on interstate commerce rather than a direct one. Just a year before, the Court had struck down every piece of New Deal legislation they got their hands on. What changed?
The change actually happened because of FDR himself. With the country clamoring for jobs programs, FDR blamed the Court for keeping these programs off the table. He proposed a mandatory retirement age for justices and an expansion of the size of the court—a plan that would have given him more Supreme Court appointments than any other president in history and ensure that he could pass whatever he wanted. The Court saw that this plan was gaining popularity, and in 1937 began to approve New Deal legislation. Pundits at the time quipped that, because it preserved the justices' jobs in the nine-justice court, it was the “switch in time that saved nine.”
Effects of the Ruling
The expansion of the Interstate Commerce clause that came about as a result of National Labor Relations Board v. Jones & Laughlin Steel Corporation would have far-reaching effects not only for the New Deal, but substantially beyond. This expansion would later be used to help ensure the constitutionality of civil rights legislation, like the Civil Rights Act of 1964.
