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Administrative Law Keyed to Koch
Universal Camera Corp. v. National Labor Relations Board
Citation:
340 U.S. 474 (1951)Facts
Universal Camera Corporation discharged an employee who had previously testified in a National Labor Relations Board proceeding. The NLRB investigated and concluded that the employee was terminated because he gave testimony under the Wagner Act, constituting an unfair labor practice. The trial examiner who initially heard the case, however, had recommended dismissal of the complaint, finding that the employee was discharged for legitimate reasons. The Board rejected the examiner’s recommendation and ordered the employee reinstated with back pay. When the case reached the Court of Appeals, that court enforced the Board’s order, holding that it was supported by substantial evidence. The court, however, refused to consider the examiner’s contrary findings as a factor in its review, believing that it was either required to treat such findings as irrelevant or to give them the same weight as a master’s findings in equity proceedings.
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