National Labor Relations Board v. Universal Camera Corp. (II)
United States Court of Appeals for the Second Circuit
190 F.2d 429 (2d Cir. 1951)
In 1946, the National Labor Relations Board (NLRB) brought a proceeding against Universal Camera Corp. (Universal) for discharging an employee for testifying under the Wagner Act. The case went to a hearing before a trial examiner of the NLRB. The trial examiner recommended that the NLRB dismiss the complaint, and issued a report finding that Universal had not discharged the employee in retaliation for his testimony. The NLRB rejected the report and ordered Universal to reinstate the employee and to cease and desist from terminating employees for this reason. The Court of Appeals for the Second Circuit upheld the order. The Supreme Court held that a court should defer to a federal agency's findings of fact if they are supported by “substantial evidence on the record considered as a whole.” It found that the Court of Appeals applied the correct standard of review. However, the Supreme Court found that the Court of Appeals did not properly take into account the examiner’s findings which are part of the record. It remanded to the Court of Appeals.
Rule of Law
Holding and Reasoning (Hand, J.)
Concurrence (Frank, J.)