NLRB v. Hearst Publications
| NLRB v. Hearst Publications | |
|---|---|
 | |
| Argued February 8–9, 1944 Decided April 24, 1944 | |
| Full case name | National Labor Relations Board v. Hearst Publications, Inc |
| Citations | 322 U.S. 111 (more) |
| Case history | |
| Prior | Court of Appeals refused to enforce the NLRB's orders, 136 F.2d 608 (reversed). |
| Holding | |
| Reviewing courts have limited review over administrative agencies' interpretation of terms in their organic statutes. The NLRB's finding that the newsboys were employees was subject to deference. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rutledge, joined by Stone, Black, Frankfurter, Douglas, Murphy, Jackson |
| Concurrence | Reed |
| Dissent | Roberts |
| Laws applied | |
National Labor Relations Act | |
NLRB v. Hearst Publications, 322 U.S. 111 (1944), was an administrative law case heard before the
National Labor Relations Act
(NLRA).
Background
Decision of the Court
Justice Rutledge, delivering the opinion of the court, ruled that the NLRB's interpretation of the Act was not erroneous. The court held that when an administrative agency engages in "specific application of a broad statutory term in a proceeding in which the agency administering the statute must determine it initially, the reviewing court's function is limited."[2] The newsboys were employees within the meaning of the Act, with whom Hearst was required to collectively bargain
.
Dissent
Justice Roberts, dissenting, wrote that "the question of who is an employee, so as to make the statute applicable to him, is a question of the meaning of the Act and, therefore, is a judicial and not an administrative question."[3]
Facts
Newsboys, who distributed papers on the streets of the city of
National Labor Relations Act
1935.
Judgment
The Supreme Court held that the Act's history, context and purposes should be taken into account when determining whether someone is an employee, not just common law standards, local law or legal classifications made for other purposes. The NLRB's determination that someone is an employee may not be set aside if it has a reasonable legal basis. Its identification of bargaining units was within its discretion, including its exclusion of suburban newsboys on the ground that they were not in the union.
Rutledge J gave the court's judgment.[4]
Reed J
concurred, and said the NLRB had the definition of 'employee' correct.
Roberts J dissented, stating his view that the newsboys were not employees.
See also
- Newsboys Strike of 1899
- List of United States Supreme Court cases, volume 322
- US labor law
References
External links
Works related to National Labor Relations Board v. Hearst Publications at Wikisource- Text of NLRB v. Hearst Publications, 322 U.S. 111 (1944) is available from: Findlaw Justia
