A union sought to unionize the buyers in the plant of Bell Aerospace Company Division of Textron Inc. (Bell) (plaintiff). Bell argued that the buyers were not subject to the National Labor Relations Act (Act) because they were “managerial employees.” When this issue was subsequently litigated before the National Labor Relations Board (NLRB) (defendant), the NLRB reversed its earlier policy that all managerial employees were exempt from the Act. Specifically, the NLRB found that only managerial employees with labor-management responsibilities were so exempt. After concluding that the buyers at Bell’s plant had no such responsibilities, the NLRB found that they were subject to the Act. On review, a federal appellate court held that although the Board was not precluded from determining that buyers were managerial employees, it could do so only through rulemaking. The United States Supreme Court granted review of the case.