Substantial Evidence Case Study

Madison Stewart 11/08/2017

POL 465 Essay 3

The Scope of Judicial Review and The Meaning of Substantial Evidence: Comparing Universal Camera Corp v. NLRB [340 U.S. 474] and Allentown Mack Sales and Service, Inc. v. NLRB [522 U.S. 359]

Substantial Evidence is a standard set by the Supreme Court that is to be followed when lower courts review agency decisions in cases involving specific clauses of the Administrative Procedures Act (codes 556 and 557). This standard states that substantial evidence is culmination of details that would lead a reasonable person to the same finding as the agency if presented with these facts and details. Cases subject to the Substantial Evidence Test are trial hearings involving administrative

Petitioners thought that they were acting in accordance of the law set by the National Labor Review Board. The law stated that if a company believes that a union has lost majority support, that company may refuse to recognize and bargain with that union. Companies may also poll their employees to gage support of the union, or request an election of union representation. Angered, the union conducted their own poll of support. When they lost their poll the union then filed complaints of unfair labor practices with the NLRB. An administrative law judge heard the case and found that Allentown Mack was bound by NLRB rules and must negotiate with the union. Allentown Mack appealed this decision. The Supreme Court found that the standard being used was sufficient, however Allentown Mack acted reasonably and consistent with the law as outlined by

that evidence of both parties’ actions must be taken into consideration, and if these facts were presented to a reasonable person that individual should come to the same conclusion as the Board. The Court also found that lower courts have the power to overturn Board decisions, although these decisions should be respected to an extent they are still subject to scrutiny by the Substantial Evidence Test. In Allentown Mack Sales, the Court found that even though the Board’s decision was reasonable and not arbitrary, the decision is subject to the Substantial Evidence test. When viewing all of the facts, including evidence supporting the actions of Allentown Mack Sales, the Substantial Evidence test favored the petitioner. In the Service, Inc. section of the Allentown Mack Sales case the Court verified that when evidentiary support is stated within an act, adjudication and rulemaking are subject to that test. These cases all deal with the scope of judicial review regarding questions of fact. The Supreme Court was consistent in these decisions and the Allentown and Services, Inc. case draws directly from the Universal Camera Corp. case to create the Substantial Evidence