Medo Photo Supply Corp. v. National Labor Relations Board

Summary

The Court affirmed enforcement of the Board's order, holding that an employer violates the National Labor Relations Act by negotiating directly with employees while their designated union remains their exclusive bargaining representative, granting wage increases to induce abandonment of that union, and then relying on the resulting loss of majority support to refuse to bargain. The employees' initiation of the negotiations did not excuse the violations. The Court did not decide the general requirements for revoking a bargaining designation or review the propriety of the affirmative bargaining remedy, which the petition did not challenge. Justice Roberts dissented without explanation. Justice Rutledge dissented separately, with no justice recorded as joining, arguing that the employees had voluntarily reclaimed their bargaining authority and that the employer merely accommodated their freely expressed wishes; he would reverse and direct dismissal of the enforcement petition.