New York Telephone Co. v. New York Department of Labor

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Unemployment insurance


Supreme Court of the United States
New York Telephone Co. v. New York Department of Labor
Reference: 440 U.S. 519
Term: 1979
Important Dates
Argued: October 30, 1978
Decided: March 21, 1979
Outcome
United States Court of Appeals for the Second Circuit affirmed
Majority
Byron WhiteJohn StevensWilliam Rehnquist
Concurring
William BrennanHarry BlackmunThurgood Marshall
Dissenting
Warren BurgerLewis PowellPotter Stewart

New York Telephone Co. v. New York Department of Labor was a case decided on May 31, 1977, by the United States Supreme Court, which ruled that New York could pay unemployment benefits to striking workers. The Supreme Court affirmed the lower court's decision and held that the payments did not conflict with the Social Security Act of 1935 or the National Labor Relations Act.[1][2]

Background

New York law allowed the payment of benefits to striking workers after an eight week waiting period. New York's experience-rated unemployment insurance system distributed the costs of unemployment benefits primarily among the employers of employees who claimed benefits.[1][2]

New York Telephone Company's employees struck for about seven months, claiming unemployment benefits for five of those months, increasing the company's unemployment tax burden. The company filed suit in district court, alleging the New York law permitting unemployment payments to striking workers after eight weeks conflicted with the the National Labor Relations Act (NLRA) and Social Security Act (SSA) under the Constitution's Supremacy Clause.[1][2]

The district court ruled that New York's law allowing unemployment payments for strikers did violate the free collective bargaining standards established in federal labor laws. The United States Court of Appeals for the Second Circuit reversed the district court, ruling that the NLRA and SSA left room for New York to allow payments to strikers.[1][2]

Oral argument

Oral argument was held on October 30, 1978. The case was decided on March 21, 1979.[1]

Decision

The Supreme Court decided 6-3 that the Social Security Act of 1935 and the National Labor Relations Act did not preempt New York from paying unemployment benefits to striking workers. Justice John Stevens, joined by Justices Byron White and William Rehnquist, announced the judgement of the court and delivered an opinion. Justice William Brennan and Justice Harry Blackmun, joined by Justice Thurgood Marshall, filed concurring opinions. Justice Lewis Powell, joined by Chief Justice Warren Burger and Justice Potter Stewart dissented.[1]

Opinions

Opinion of the court

Justice John Stevens, writing for the court, argued that the Social Security Act of 1935 and the National Labor Relations Act did not preempt New York from paying unemployment benefits to striking workers:[1]

Because New York's program, like those in other States, is financed in part by taxes assessed against employers, it is not, strictly speaking, a public welfare program. It nevertheless remains true that the payments to the strikers implement a broad state policy that does not primarily concern labor-management relations, but is implicated whenever members of the labor force become unemployed. Unlike most States, New York has concluded that the community interest in the security of persons directly affected by a strike outweighs the interest in avoiding any impact on a particular labor dispute. As this Court has held in a related context, such unemployment benefits are not a form of direct compensation paid to strikers by their employer; they are disbursed from public funds to effectuate a public purpose. ...


Our review of both the statute and its legislative history convinced us that Congress had not intended to prescribe the nationwide rule that Hodory urged us to adopt. The voluminous history of the Social Security Act made it abundantly clear that Congress intended the several States to have broad freedom in setting up the types of unemployment compensation that they wish. We further noted that, when Congress wished to impose or forbid a condition for compensation, it did so explicitly; the absence of such an explicit condition was therefore accepted as a strong indication that Congress did not intend to restrict the States' freedom to legislate in this area.[3]

—Justice John Stevens, majority opinion in New York Telephone Co. v. New York Department of Labor[1]

Concurring opinions

Justice William Brennan and Justice Harry Blackmun, joined by Justice Thurgood Marshall, filed concurring opinions agreeing with the Steven's opinion based on historical analysis of the Social Security Act of 1935 and the National Labor Relations Act. They disagreed with Steven's interpretation of precedent in the case.[1]

Dissenting opinions

Justice Lewis Powell, writing the dissent, argued that the free collective bargaining standards established under the Social Security Act of 1935 and the National Labor Relations Act preempted New York from paying unemployment benefits to striking workers:[1]

The Court's decision substantially alters, in the State of New York, the balance of advantage between management and labor prescribed by the National Labor Relations Act (NLRA). It sustains a New York law that requires the employer, after a specified time, to pay striking employees as much as 50% of their normal wages. In so holding, the Court substantially rewrites the principles of preemption that have been developed to protect the free collective bargaining which is the essence of federal labor law.[3]
—Justice Lewis Powell, dissenting opinion in New York Telephone Co. v. New York Department of Labor[1]

See also

External links

Footnotes