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    SmartBrief enables case brief popups that define Key Terms, Doctrines, Acts, Statutes, Amendments and Treatises used in this case.

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    Constitutional Law Keyed to Barnett

    View this case in different Casebooks
    Constitutional Law Keyed to MaggsConstitutional Law Keyed to Choper

    NLRB v. Jones & Laughlin Steel Corp.

    Citation:

    301 U.S. (1937)
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    Facts

    In 1935, Congress passed the National Labor Relations Act to create better working conditions for employees and protect their right to organize in unions. The National Labor Relations Board, the executive agency tasked with enforcing the law, found that respondent Jones & Laughlin Steel Corporation had engaged in unfair labor practices (thus violating the NLRA) by discriminating against employees who were attempting to form a union. Jones & Laughlin was a major producer of steel in the U.S., with business and offices in many states. The NLRB ordered a steel manufacturer, Jones & Laughlin, to remedy the unfair employment practices. Jones & Laughlin sued, arguing that the NLRA was unconstitutional as an impermissible use of Congress’s Commerce Power.

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    Q.1 - In rejecting earlier Commerce Clause doctrine, Jones & Laughlin modified which core distinction that had previously limited federal regulatory authority over economic activity?
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    Incorrect. A is incorrect because the Court did not confine Congress to regulating only shipments or physical transportation across state lines.
    Incorrect. B is incorrect because Congress's authority is not limited to formal commercial transactions alone.
    Correct! The Court departed from E.C. Knight’s artificial distinction between manufacturing and commerce, recognizing that production activity substantially affecting commerce falls within Congress’s regulatory reach.
    Incorrect. D is incorrect because regulation was not confined to transportation infrastructure but included broader economic activity.
    Q.2 - Which interpretive principle did the Court adopt in Jones & Laughlin to justify federal regulation of intrastate labor disputes under the Commerce Clause?
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    Incorrect. A is incorrect because the Court did not require proof of a direct causal relationship for every particular instance.
    Correct! The Court adopted the substantial effects test, permitting regulation of intrastate activity where its aggregate economic consequences endanger interstate commerce.
    Incorrect. C is incorrect because regulation requires substantial, not merely incidental, effects on commerce.
    Incorrect. D is incorrect because judicial review was retained; Congress’s findings were not entirely insulated from review.
    Q.3 - Which constitutional development most directly traces its doctrinal lineage to the analytical shift introduced in Jones & Laughlin?
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    Incorrect. A is incorrect because National League of Cities involved Tenth Amendment limits on federalism, not Commerce Clause expansion.
    Incorrect. B is incorrect because Swift predates Jones & Laughlin and involved the stream of commerce doctrine, not substantial effects aggregation.
    Incorrect. C is incorrect because the anti-commandeering doctrine addresses vertical separation of powers, not Commerce Clause scope.
    Correct! Wickard v. Filburn extended Jones & Laughlin’s aggregation principle, allowing regulation of entirely local conduct when its cumulative economic impact burdens interstate commerce.

    Topic Resources

    ™ CaseCast

    Matthew Steinberg

    InstructorMatthew Steinberg

    CaseCast™ "What you need to know"

    CaseCast™ –  "What you need to know"

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    Topic Video

    NLRB v. Jones & Laughlin Steel Corp.9m 38s
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    Topic Outline

    Powers of Congress

    Topic Charts & Notes

    Powers Chart State Regulation of Interstate Commerce

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