Supreme Court of the United States

National Labor Relations Board v. Walton Manufacturing Co.

April 9, 1962369 U.S. 404

Summary

The Supreme Court reversed the Fifth Circuit’s refusal to enforce NLRB reinstatement orders, holding that the appellate court must apply the uniform substantial‑evidence standard articulated in Universal Camera rather than the special credibility test from Tex‑O‑Kan; the cases were remanded for reconsideration. Justice Frankfurter’s dissent argued the majority mischaracterized the lower courts’ approach and would have affirmed the judgments.

Holding

  • Whether the Fifth Circuit erred by applying the Tex‑O‑Kan credibility rule to reinstatement orders. The Fifth Circuit’s use of the Tex‑O‑Kan rule was erroneous; appellate review must follow the substantial‑evidence standard articulated in Universal Camera, and the reinstatement orders should be enforced.
  • Whether a uniform substantial‑evidence standard applies to all NLRB orders. All NLRB orders, including those requiring reinstatement with back pay, are subject to the same substantial‑evidence standard; the appellate court must not apply a distinct rule for reinstatement cases.

Docket 77

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