Universal Camera Corp. v. Labor Board,
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340 U.S. 474 (1951)
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U.S. Supreme Court
Universal Camera Corp. v. Labor Board, 340 U.S. 474 (1951)
Universal Camera Corp. v. National Labor Relations Board
Argued November 6-7, 1950
Decided February 26, 1951
340 U.S. 474
The National Labor Relations Board ordered petitioner to reinstate with back pay an employee found to have been discharged because he gave certain testimony in another proceeding under the National Labor Relations Act. The evidence as to the reason for his discharge was conflicting, and the Board overruled its examiner's findings of fact and his recommendation that the proceedings be dismissed. In decreeing enforcement, the Court of Appeals held that the Board's findings of fact were "supported by substantial evidence on the record considered as a whole" within the meaning of § 10(e) of the National Labor Relations Act, as amended in 1947. This holding was based partly on the view (1) that the 1947 amendments had not broadened the scope of judicial review, and (2) 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.
1. In the light of the legislative history, the standard of proof required under § 10(e) of the National Labor Relations Act, as amended by the Labor Management Relations Act, 1947, to support a decision of the Labor Board on judicial review is the same as that to be exacted by courts reviewing every administrative action subject to the Administrative Procedure Act. Pp. 340 U. S. 477-487.
2. In amending § 10(e) of the National Labor Relations Act so as to require that, on judicial review, the Board's findings of fact must be supported by substantial evidence "on the record considered as a whole," Congress made it clear that a reviewing court is not barred from setting aside a Board decision when it cannot conscientiously find that the evidence supporting that decision is substantial, when viewed in the light that the record in its entirety furnishes, including the body of evidence opposed to the Board's view. Pp. 340 U. S. 487-488.
3. When read in the light of their legislative history, the Administrative Procedure Act and the Labor Management Relations Act,
1947, require the courts to assume more responsibility for the reasonableness and fairness of Labor Board decisions than some courts have shown in the past. Pp. 340 U. S. 488-490.
4. Whether, on the record as a whole, there is substantial evidence to support agency findings is a question which Congress has placed in the keeping of the courts of appeals. This Court will intervene only in what ought to be the rare instance when the standard appears to have been misapprehended or grossly misapplied. P. 340 U. S. 491.
5. The Court of Appeals erred in holding that it was barred from taking into account the report of the examiner on questions of fact insofar as that report was rejected by the Board. Pp. 340 U. S. 491-497.
(a) A trial examiner's findings are not as unassailable as a master's, and may be reversed by the Board when when not clearly erroneous. P. 340 U. S. 492.
(b) A reviewing court need not give a trial examiner's findings more weight than, in reason and in the light of judicial experience, they deserve, but they should be accorded the relevance that they reasonably command in answering the comprehensive question whether the evidence supporting the Board's order is substantial. Pp. 340 U. S. 496-497.
6. The cause is remanded to the Court of Appeals, which is left free to grant or deny enforcement as it thinks the principles expressed in the opinion, of this Court dictate. P. 340 U. S. 497.
179 F. 2d 749, vacated and remanded.
The Court of Appeals decreed enforcement of an order of the National Labor Relations Board requiring petitioner to reinstate an employee with back pay and to cease and desist from discriminating against any employee who files charges or gives testimony under the National Labor Relations Act. 179 F.2d 749. This Court granted certiorari. 339 U.S. 962. Judgment vacated and cause remanded, p. 340 U. S. 497.