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Universal Camera Corp. v. National Labor Relations Board

United States Supreme Court
340 U.S. 474 (1951)

Facts

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. Universal petitioned the Supreme Court for certiorari, arguing that (1) the Second Circuit erred in holding that it was barred from taking into account the report of the examiner on questions of fact because that report was rejected by the NLRB; and (2) the NLRB’s order was not supported by substantial evidence on the record as a whole.

Rule of Law

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Issue

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Holding and Reasoning (Frankfurter, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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