Office Employes International Union, Local No. 11 v. National Labor Relations Board

1957-06-17

Headline: Court holds labor unions are employers for their own workers and blocks the Board’s blanket refusal to assert jurisdiction, making unions acting as employers subject to federal labor-law rules.

Holding:

Real World Impact:

Makes unions subject to federal labor-law rules when they employ staff.
Stops the Board from exempting all unions as employers without case-by-case review.
Allows union-employed clerical workers to seek Board elections and protections.

Topics: union employers, federal labor board jurisdiction, workers employed by unions, definition of employer

Summary

Background

A local union (Local 11) tried to represent office-clerical workers who were employed by several Teamster organizations that occupied the Teamsters Building in Portland, Oregon. Local 11 filed unfair labor practice complaints saying the Teamster group interfered with its organizing effort. The National Labor Relations Board dismissed the complaints, the Court of Appeals affirmed, and the Supreme Court agreed to decide the jurisdictional question.

Reasoning

The key question was whether a labor organization counts as an “employer” when it hires and pays its own staff. The Court looked to the plain language of the law and its legislative history and concluded Congress meant unions to be covered “when acting as an employer.” The Board was wrong to treat all unions as a class exempt from the Act. The Court reversed the Board’s refusal to assert jurisdiction and sent the case back for further proceedings on that basis.

Real world impact

Unions that hire clerical or other employees must be treated like employers under federal labor law when they act in that role. The decision requires the federal labor board to consider jurisdiction and cases involving union employers rather than automatically excluding them. This ruling addresses jurisdiction only; the Court did not decide whether any unfair labor practices actually occurred, so final outcomes on the complaints may still change.

Dissents or concurrances

A separate opinion agreed that unions are employers but argued the Board should have discretion to decline jurisdiction in some cases; that view would send the issue back for the Board to reconsider.