Black v. Cutter Laboratories

Background

An employee, Mrs. Doris Walker, was discharged by Cutter Laboratories after the company concluded she falsified her job application and was a Communist. Her union pursued reinstatement through an arbitration board, which found she was fired for union activity and ordered her reinstated. California trial and intermediate appellate courts enforced that award, but the Supreme Court of California reversed, holding the collective-bargaining “just cause” clause could support discharge for Party membership.

Reasoning

The U.S. Supreme Court reviewed whether the state decision raised a substantial federal constitutional question under the Fourteenth Amendment. The majority concluded the California court’s ruling rested on state contract interpretation and waiver principles, not on a federal constitutional basis, so no federal question justified further review and the writ was dismissed. The Court emphasized it reviews judgments, not broad language in opinions.

Real world impact

Because the high Court declined review, the California decision reversing reinstatement remains in effect in that case, and the state court’s contract construction controls. The outcome affects how local labor contracts and arbitration awards can be enforced when employers cite political affiliation. This dismissal is not a Supreme Court ruling on the constitutional limits of firing for political belief.

Dissents or concurrances

Justice Douglas (joined by the Chief Justice and Justice Black) dissented, arguing the California opinion plainly upheld the discharge because of Communist affiliation and directly raised First and Fourteenth Amendment issues, warning that court enforcement of such contracts risks unconstitutional discrimination against political belief.