Magnolia Petroleum Co. v. National Labor Relations Board

112 F.2d 545, 6 L.R.R.M. (BNA) 808, 1940 U.S. App. LEXIS 4344
CourtCourt of Appeals for the Fifth Circuit
DecidedJune 13, 1940
Docket9382
StatusPublished
Cited by34 cases

This text of 112 F.2d 545 (Magnolia Petroleum Co. v. National Labor Relations Board) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Magnolia Petroleum Co. v. National Labor Relations Board, 112 F.2d 545, 6 L.R.R.M. (BNA) 808, 1940 U.S. App. LEXIS 4344 (5th Cir. 1940).

Opinion

HUTCHESON, Circuit Judge.

This is a proceeding, on the one hand to review and set aside, on the other to enforce, an order of the Labor Board. Like so many others which have been brought before this and other Circuit Courts of Appeals, this proceeding takes its spring from long continued and unsuccessful efforts of a nationally affiliated labor union to organize and exclusively represent workers in a plant which has and has had, a local unaffiliated labor organization. Here, as in all the similar cases, the national union makes and the Board sponsors the charge that the local unaffiliated unión is not the result of self-organization of the employees but of unfair labor practices on the part of the employer in dominating and *547 interfering with or contributing support to it. The proceeding arose in this way. On April 2, 1938, local union 243, an affiliated organization, filed a petition requesting investigation and certification of representatives and on April 11, four days after the Independent was formed, the local filed charges with the Regional Director that petitioner had engaged in and was engaged in certain unfair labor practices in fonn-ing, dominating and contributing to the Independent.

On April 30, the Board authorized the Regional Director to conduct an investigation and provide for a hearing in the certification proceeding, and on May 9, the Employee’s Independent Union of Magnolia Refinery workers appeared, claiming to represent employees directly affected by the investigation. Whereupon, on motion made by counsel for the Board and joined in by counsel for local No. 243, the trial examiner postponed the hearing and on SÍay 16, the Board ordered the representation proceeding and the proceeding arising from the charges filed by local No. 243, to be consolidated for the purpose of the hearing. As the result of that hearing, the Board made the findings and order which are attacked in this case.

Petitioner here insists that the findings, that it has been guilty of unfair labor practices and the order that it desist, are wholly without support in the evidence, while the Board on its part insists that both findings and order are well supported. What is in question here then is simply and solely a question of law, whether within the meaning of Sec. 160, Title 29 U.S.C.A., and the decisions under it, the Board’s findings and order are supported by substantial evidence. Washington, Virginia & Maryland Coach Co. v. National Labor Relations Board, 301 U.S. 142-147, 57 S.Ct. 648, 81 L.Ed. 965. “Substantial evidence is more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Edison Co. v. Labor Board, 305 U.S. 197, 229, 59 S.Ct. 206, 217, 83 L.Ed. 126. That is, the evidence relied on to give conclusiveness to the Board’s fact findings must be “evidence which is substantial, that is, affording a substantial basis of fact from which the fact in issue can be reasonably inferred. * * * it must be enough to justify, if the trial were to a jury, a refusal to direct a verdict when the conclusion sought to be drawn from it is one of fact for the jury.” Labor Relations Board v. Columbian Co., 306 U.S. 292, 299-300, 59 S.Ct. 501, 505, 83 L.Ed. 660. 1

A careful examination of the record discloses no substantial conflict in the evidence. The question for decision here, the same as that which arises in common law cases tried to a jury, is whether the undisputed evidence, with the reasonable fact inferences to be drawn therefrom, supports the verdict, that is, whether reasonable and impartial minds could, upon the evidence, have reached the conclusion the Board did.

The statute in conferring upon the Board jurisdiction both to accuse and to try, to prosecute and to decide, charges of unfair labor practices, confers these mutually antagonistic powers with full recognition of and in full subordination to, the principles, at once of natural right and of constitutional law, that no man may be a judge in his own cause and that accusation is neither proof nor evidence of guilt. To preserve these principles from corruption, the Statute, while giving wide and flexible powers of inquiry and hearing to the Board, yet insures, to every person affected by its orders, that his cause will be fairly adjudged, by providing, as an essential to enforcement of an order, that there be a judicial review upon the question whether, and a determination that, the order is supported by evidence. Contrary to the expressed view of some, that the Congress in enacting this legislation, was more concerned with expedition and specialization than with preserving these fundamental principles, more concerned with getting questions decided, than with getting them justly decided, the whole structure of the act as well as the whole course of informed judicial decision under it, makes it plain that this is not so. The enforcing section of the act 2 particularly shows that the Congress was primarily concerned to insure *548 that the Board as accuser, must, in order to obtain enforcfement of its order, secure judicial approval of its findings as trier, as supported by evidence, and thus afford the accused the due process of having the verdict of the Labor Board as trier, judicially reviewed and decided by the Circuit Courts of Appeals by the rules and standards applied to review of jury verdicts.

In this view, those misjudge the people and the Congress who, querulously complain that courts substitute their appraisal of the evidence for that of the Board, if they mean by that complaint that Congress has conferred upon the Board power not only to make conclusive findings, when in the opinion of the courts, these findings are supported by evidence, but power to conclusively determine, beyond judicial review, that these findings are so supported. Nothing in the genius of the American people and of the institutions they have founded and cherished, nothing in the history of the long struggle of English speaking peoples against the arbitrary and despotic exercise by Governments of seated power, nothing in the statute, nothing in the decisions of the courts, rightly' supports this view. Nothing in the well established and clearly recognized principle, that an administrative board may constitutionally and fairly exercise both accusatorial and trial functions at all supports it. 3 On the contrary, that principle as established and applied in America refutes this view.

In its capacity as accuser, the Board, under the genius of our institutions, is held to the same burdens and obligations of proof as any other litigant who takes the affirmative. It may not by accusing put the accused upon proof. As accuser it must prove its charge.

In its capacity as a trier of facts, the Board stands on the footing of a jury. Like a jury it must be impartial.

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Bluebook (online)
112 F.2d 545, 6 L.R.R.M. (BNA) 808, 1940 U.S. App. LEXIS 4344, Counsel Stack Legal Research, https://law.counselstack.com/opinion/magnolia-petroleum-co-v-national-labor-relations-board-ca5-1940.