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Administrative Law Keyed to Breyer
Universal Camera Corp. v. National Labor Relations Board
Citation:
340 U.S. 474 (1951)Facts
Universal Camera Corporation was charged with committing an unfair labor practice by discharging an employee who had testified at a National Labor Relations Board proceeding under the Wagner Act. The case was initially heard by an NLRB examiner who made findings of fact after observing witnesses and evaluating testimony. The examiner’s findings were rejected by the Board, which concluded that the employee’s discharge was motivated by his testimony at the Board hearing and thus constituted an unfair labor practice. The Board ordered Universal Camera to reinstate the employee with back pay and to cease and desist from discriminating against employees who file charges or give testimony under the Act. Universal Camera sought review in the Court of Appeals for the Second Circuit, which enforced the Board’s order. The Second Circuit held that it was bound by the Board’s rejection of the examiner’s findings and that it could not consider those findings in its review.
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