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Law School Case Brief

J. I. Case Co. v. NLRB - 321 U.S. 332, 64 S. Ct. 576 (1944)

Rule:

Individual contracts, no matter what the circumstances that justify their execution or what their terms, may not be availed of to defeat or delay the procedures prescribed by the National Labor Relations Act looking to collective bargaining, nor to exclude the contracting employee from a duly ascertained bargaining unit; nor may they be used to forestall bargaining or to limit or condition the terms of the collective agreement. The National Labor Relations Board asserts a public right vested in it as a public body, charged in the public interest with the duty of preventing unfair labor practices. Wherever private contracts conflict with its functions, they obviously must yield or the Act would be reduced to a futility. 

Facts:

Petitioner J. I. Case Company (Case) offered its employees individual employment contracts, which some of the employees accepted. The contracts governed certain employment conditions. A union was certified and won an election to become the exclusive bargaining representative of Case's employees. Case refused to bargain with the union concerning matters contained within the employment contracts it had with its employees. Case sent a circular to its employees asserting the validity of the individual contracts. National Labor Relations Board (NLRB) held that Case had violated the National Labor Relations Act by refusing to bargain collectively. The court of appeals granted an order of enforcement. 

Issue:

Was the employer's reliance on its individual contracts made with some of its employees to refuse to bargain with the elected union proper?

Answer:

No

Conclusion:

The Supreme Court modified and affirmed the court of appeals' decision, finding that Case's reliance on its individual contracts made with some of its employees to refuse to bargain with the elected union was improper because individual contracts made with employees, which could be permissible in some circumstances, could not be used to prevent employees from taking advantage of benefits afforded them in a collective agreement.

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