Friday, November 1, 2013

National Labor Relations Board v. Universal Camera Corp. case brief

National Labor Relations Board v. Universal Camera Corp. case brief summary
190 F.2d 429 (2d Cir. 1951)

CASE SYNOPSIS
The United States Supreme Court vacated the court's original order and remanded for reconsideration after it determined that the findings of the examiner were not to have been altogether disregarded in determining whether the findings of petitioner, the National Labor Relations Board, against respondent employer were supported by substantial evidence.

CASE FACTS
A discharged employee filed a complaint with the National Labor Relations Board. An examiner made findings of fact and recommended dismissal of the complaint. The Board overruled its examiner's findings of fact. In the first appeal, the court affirmed the Board's decision, finding that the Board's rejection of its examiner's findings of fact was without relevance in determining whether the Board's findings were supported by substantial evidence.

DISCUSSION
  • The United States Supreme Court vacated the court's original decision and remanded for reconsideration because the court erred in holding that it was barred from taking into account the report of the examiner on questions of fact insofar as the Board rejected that report. 
  • On remand, the court found that the examiner's determination supported a finding that the employee was not discharged as the result of any joint plan between the officers of respondent employer. 
  • Upon a reexamination of the record as a whole and upon giving weight to the examiner's findings in compliance with the Supreme Court's directions, the court held that its first disposition of the appeal was incorrect. 
  • The court reversed the order and dismissed the complaint.

OUTCOME

The court reversed its original order and dismissed the employee's complaint.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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