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J.I. Case Co. v. National Labor Relations Board

United States Supreme Court
321 U.S. 332, 64 S.Ct. 576, 88 L.Ed 762 (1944)


Facts

J.I. Case Co. (defendant) offered its workers individual one-year employment contracts with uniform terms. About 75 percent of the employees accepted the contract. While the contracts for 1941 were still effective, a union petitioned the National Labor Relations Board (plaintiff) for recognition as exclusive bargaining representative for the plant’s production and maintenance workers. The company objected, insisting that the individual employment contracts precluded representation. The board nonetheless ordered an election, the union won, and the board certified it to represent the plant workers. However, the company still refused to bargain with the union about anything the individual contracts covered. The company offered to negotiate only noncovered terms and said it would bargain as to everything else only when the 1941 contracts expired. In addition, the company sent out two circulars to its employees, asserting that the contracts remained valid and explaining its position with the union. The board found that the company refused to bargain collectively and used the contracts to impede employees’ rights, which amounted to unfair labor practices. As a result, the board ordered the company to stop enforcing the contracts to avoid bargaining with the union.

Rule of Law

Issue

Holding and Reasoning (Jackson, J.)

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