Carroll College, Inc. v. N.L.R.B.

Carroll College (plaintiff) was a private, nonprofit college associated with the Synod of Lakes and Prairies of the United Presbyterian Church. According to the college’s articles of incorporation, the college’s purpose was to operate as a Christian liberal-arts college. The United Automobile, Aerospace & Agricultural Implement Workers of America filed a petition with the National Labor Relations Board (NLRB) (defendant) to be certified as the collective-bargaining representative for the faculty at the college. The college responded that requiring it to bargain with a union would violate the college’s rights under the Religious Freedom Restoration Act (RFRA). Specifically, the college argued that the NLRB had no jurisdiction over the college as a religious organization. The regional director of the NLRB ruled that because the college was not “church operated,” the college was subject to the jurisdiction of the NLRB. The college requested a review from the NLRB, which found that requiring the college to recognize and bargain with the union did not violate the RFRA. The college appealed to the federal court of appeals. On appeal, the college abandoned the argument regarding the RFRA and instead argued that the religious clauses of the First Amendment prevented the NLRB from exercising jurisdiction over the college because the college was a nonprofit, religious institution affiliated with a recognized religious organization.