NLRB v. Columbian Enameling & Stamping Co., 306 U.S. 292 (1939), is a US labor law case where the US Supreme Court held 5-to-2 that the National Labor Relations Act required decisions of the National Labor Relations Board (Board) to be based on substantial evidence. The Supreme Court overturned a ruling of the Board (requiring an employer to rehire striking workers) for not being based on substantial evidence. The Court also held that only the representative of the workers (the union) could issue collective bargaining proposals under the law, and that proposals transmitted by a third party did not trigger the Act's protections or duties. Facts Columbian Enameling & Stamping Co. manufactured metal utensils in Terre Haute, Indiana. It recognized a labor union of its employees and signed a one-year collective bargaining agreement on July 14, 1934, which provided for arbitration of disputes and barred work stoppages (pending arbitration). Over the next seven months, the company and union met repeatedly to discuss and negotiate over the union's demands, which included a closed shop and the dismissal of all workers the union had suspended for non-payment of dues. The union struck on March 23, 1935, and the strike turned into a lockout on March 30. The plant reopened with strikebreakers on July 23, 1935. During the strike, the National Labor Relations Act (NLRA) became law. The Board attempted to mediate an end to the strike in July and August, but to no avail. The union submitted proposals to the employer in September and October, but received no reply. On February 14, 1936, the NLRB held Columbian Enameling & Stamping in violation of the NLRA for refusing to bargain in good faith with its workers, and ordered all strikebreakers fired and all former employees rehired. The company sued in federal court to have the order overturned. Judgment Associate Justice Harlan F. Stone wrote the decision for the majority, joined by Chief Justice Charles Evans Hughes and Associate Justices James Clark McReynolds, Pierce Butler, and Owen Roberts. Stone concluded that the NLRB's decision was not supported by the evidence. The NLRB agents' proposals to the employer did not constitute a request for bargaining under the NLRA, and so the employer's refusal to respond to them was not a violation of the law. The NLRB's conclusions, Stone said, were not based on "substantial" evidence. The majority defined substantial evidence as evidence which "must do