Universal Camera Corp. V. NLRB - Decision

Decision

Justice Frankfurter delivered the opinion of the Court. The Court discussed the "substantial evidence" test established by the Court in Consolidated Edison Co. v. NLRB, which interpreted the Wagner Act, the original National Labor Relations Act. The Act provided that "he findings of the Board as to the facts, if supported by evidence, shall be conclusive."

The Con Edison court read "evidence" to mean "substantial evidence." "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."

The Court reviewed the Act's legislative history, concluding that "t is fair to say that in all this Congress expressed a mood... As legislation that mood must be respected." The Court found that both the Administrative Procedure Act and the Taft-Hartley Act, which amended the National Labor Relations Act, required that courts consider the whole record. In weighing the substantiality of evidence, courts must thus consider the whole body of evidence, including views opposed to the ultimate decision.

Justices Black and Douglas concurred only in parts I and II of the opinion, dissenting from part III.

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