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 decisions, holding that the proper standard of review for National Labor Relations Board reinstatement orders is the uniform substantial‑evidence test articulated in Universal Camera and Pittsburgh S.S. Co., not the special credibility rule from Tex‑O‑Kan; the cases are remanded for reconsideration. Justice Frankfurter’s dissent argued the Court misapplied the law and would have affirmed the lower rulings.
Holding
- Whether the Fifth Circuit erred by applying a special credibility rule from Tex‑O‑Kan to NLRB reinstatement orders instead of the uniform substantial‑evidence standard.. The Fifth Circuit’s application of the Tex‑O‑Kan rule was erroneous; the proper standard is the substantial‑evidence test, and the decisions are reversed and remanded.
Docket 77