HomeCase briefs › Constitutional Law

National Labor Relations Board v. Friedman-Harry Marks Clothing Co.

Supreme Court of the United States · 1937 · Constitutional Law
Constitutional LawCommerce ClauseLabor LawCommerce ClauseNational Labor Relations ActNLRBinterstate commerceunfair labor practices

Facts

Respondent, a Virginia corporation, manufactured men's clothing in Richmond. Nearly all of its principal materials came from outside Virginia, and most of its finished garments were sold to customers outside the state, with part of its sales made through a New York office. The Board found that respondent opposed its employees' unionization, threatened discharge for attending union meetings, maintained surveillance over union activities, and discharged certain employees because of their union membership and activities. The Board also found that such interference in the clothing industry had led and tended to lead to strikes and labor disputes burdening and obstructing commerce.

Issue

Whether the National Labor Relations Act constitutionally applied to respondent's labor practices toward its manufacturing employees, and whether the Board's orders based on those practices could be enforced.

Rule

For the reasons stated in National Labor Relations Board v. Jones & Laughlin Steel Corp., the National Labor Relations Act validly applies to unfair labor practices of an employer whose operations have the requisite relation to interstate commerce, and objections to the Act's construction and constitutionality are without merit where the Board's findings are supported by evidence.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

  • The court's holding and reasoning
  • Doctrine tests, pitfalls & exam hypotheticals
  • 10 practice questions + 4 AI-graded essays on this case
Sign up free to see more →
Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.
Lakefront Uniform Works, a corporation operating a single plant in Cleveland, buys 96% of its fabric from suppliers in North Carolina and Georgia and ships 78% of its finished uniforms to retailers in Michigan, Indiana, and Pennsylvania. After workers begin joining a garment workers' union, managers threaten to fire anyone who attends union meetings and then discharge several organizers.

If the Board finds those facts supported by evidence, is federal regulation of the employer's labor practices most likely constitutional?

Explanation. The majority held that the Act validly applies where the employer's business has the requisite relation to interstate commerce and the Board's findings show anti-union discharges and interference tending to lead to labor disputes burdening commerce. A single manufacturing plant may qualify when it depends heavily on interstate inflow of materials and interstate outflow of finished goods. (Derived from National Labor Relations Board v. Friedman-Harry Marks Clothing Co. (n.d.).)