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Key Supreme Court Cases on Labor Law
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Caterpillar Inc. v. Williams (1987)
Significance: Clarified what cases could be moved from state courts to federal courts. Ruling: The Court held that a federal question jurisdiction could not be based on anticipated defenses but must be an element of the plaintiff's original claim.
Burlington Industries, Inc. v. Ellerth (1998)
Significance: Established standards for employer liability in cases of workplace harassment. Ruling: The Court held that employers are liable for sexual harassment by supervisors, even if the victim does not suffer a tangible job detriment if the employer failed to exercise reasonable care to prevent and correct promptly any sexually harassing behavior.
Employment Division, Department of Human Resources of Oregon v. Smith (1990)
Significance: Addressed the balance between religious freedom and state laws affecting employment. Ruling: The Court held that the state could deny unemployment benefits to a worker fired for using illegal drugs for religious purposes.
Epic Systems Corp. v. Lewis (2018)
Significance: Asserted the enforceability of arbitration agreements in employment contracts. Ruling: The Court held that employment agreements that contain arbitration clauses to settle disputes are enforceable, and do not violate the National Labor Relations Act.
National Labor Relations Board v. Fansteel Metallurgical Corp. (1939)
Significance: The case limited the power of the National Labor Relations Board in cases of employee misconduct. Ruling: The Court ruled that the NLRB could not order the reinstatement of workers who had seized property during a sit-down strike.
Adkins v. Children's Hospital (1923)
Significance: Overturned a minimum wage law for women and children in the District of Columbia. Ruling: The Court held that the law violated the due process right of employers and employees to enter into contracts with each other freely.
Lechmere, Inc. v. National Labor Relations Board (1992)
Significance: Addressed the rights of non-employee union organizers to access employer property. Ruling: The Court held that non-employee union organizers do not have a federal statutory right to enter an employer's property to organize workers.
Gibbons v. Ogden (1824)
Significance: Early case underlining federal authority over interstate commerce, impacting labor regulations. Ruling: The Court established the supremacy of federal power over interstate commerce as opposed to state-enacted legislation.
New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Insurance Co. (1995)
Significance: Touched on the issue of state versus federal powers concerning laws that indirectly affect employee benefits. Ruling: The Court held that not all state laws affecting employee benefit plans are pre-empted by federal law (ERISA).
Smith v. City of Jackson, Mississippi (2005)
Significance: Considered the applicability of the Age Discrimination in Employment Act (ADEA) in disparate impact claims. Ruling: The Court held that employees could file disparate impact claims under the ADEA, even if the discrimination was unintentional.
Wolff Packing Co. v. Court of Industrial Relations of Kansas (1923)
Significance: This case tackled state intervention in labor disputes. Ruling: The Court invalidated a Kansas law that established wage boards to determine work conditions, finding it violated due process.
Youngstown Sheet & Tube Co. v. Sawyer (1952)
Significance: Limited the power of the President to seize private property in the absence of either specifically enumerated authority under Article II of the Constitution or statutory authority conferred on him by Congress. Ruling: The Court held that the President lacked the authority to seize the steel mills in question to avert a strike during the Korean War.
Ford Motor Co. v. NLRB (1979)
Significance: Concerned the unilateral changes in unionized work settings. Ruling: The Court held that an employer must bargain with the union before making any substantial change to terms or conditions of employment.
Steelworkers v. Weber (1979)
Significance: Considered the legality of affirmative action in private sector employment. Ruling: The Court held that the Civil Rights Act of 1964 did not bar employers from favoring underrepresented groups if the purpose was to eliminate racial imbalance in traditionally segregated job categories.
Thomas v. Review Board of the Indiana Employment Security Division (1981)
Significance: Addressed the free exercise of religion in the workplace. Ruling: The Court determined that the state must accommodate an employee's religious beliefs when it comes to conditions of employment, as long as the accommodation does not constitute an undue hardship for the employer.
Golden State Transit Corp. v. City of Los Angeles (1989)
Significance: Addressed federal preemption in the field of labor relations. Ruling: The Court held that the National Labor Relations Act pre-empted a municipal ordinance that infringed upon the domain of labor relations managed federally.
Steward Machine Co. v. Davis (1937)
Significance: Upheld provisions of the Social Security Act of 1935 relating to unemployment compensation. Ruling: The Court determined that the act's unemployment compensation provisions were a valid exercise of Congress's power under the Taxing Clause and General Welfare Clause.
United Steelworkers of America v. Enterprise Wheel and Car Corp. (1960)
Significance: Addressed the enforcement of arbitration awards in collective bargaining agreements. Ruling: The Court held that courts must enforce arbitration awards if they derive from the contract and are not in clear disregard of its terms.
Lochner v. New York (1905)
Significance: Established limits on the states' power to regulate labor conditions and led to the development of the so-called 'Lochner era'. Ruling: The Court struck down a New York law setting maximum working hours for bakers, asserting that the law interfered with individuals' liberty of contract.
West Coast Hotel Co. v. Parrish (1937)
Significance: Ended the Lochner era by upholding Washington State's minimum wage law for women. Ruling: The Court held that the state had a valid interest in protecting the health and welfare of women workers.
Lincoln Federal Labor Union v. Northwestern Iron & Metal Co. (1949)
Significance: Assessed the constitutionality of 'right to work' laws. Ruling: The Court upheld the right of states to pass 'right to work' laws, which allow laws prohibiting union security agreements.
International Brotherhood of Teamsters v. United States (1977)
Significance: Dealt with issues of racial discrimination in the context of seniority systems at workplaces. Ruling: The Court held that the government could challenge discriminatory employment practices utilizing a pattern or practice theory, and relief could include individuals who were non-applicants during the discrimination period.
Grocery Store Co. v. United Food and Commercial Workers Union, Local 455 (1984)
Significance: Addressed unions' rights to picket and economic activity outside of workplace settings. Ruling: The Court clarified the balancing of free speech rights of unions with private property rights of business owners.
National Labor Relations Board v. Jones & Laughlin Steel Corporation (1937)
Significance: Upheld the National Labor Relations Act of 1935, ensuring federal protection for workers' right to organize and collectively bargain. Ruling: The Court decided that labor management disputes were within the reach of the Commerce Clause, thus the federal government could regulate labor relations in companies affecting interstate commerce.
Communication Workers of America v. Beck (1988)
Significance: Addressed the use of union dues for political activities in relation to non-union employees. Ruling: The Court held that non-union employees could not be compelled to pay for union activities unrelated to collective bargaining, contract administration, or grievance adjustment.
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