that strikebreakers were not eligible to participate in union organizing elections, the Millis Board voted in In Rudolph Wurlitzer Co., 32, NLRB 163 (1941) to overturn that precedent. The Madden Board had held in Inland Steel, 9 NLRB 783 (1938) that a company was responsible for actions of its foremen, but the Millis Board overturned this decision in Joseph E. Seagram & Sons, Inc., 32 NLRB 1056 (1941). The Madden Board had ruled several times that an employer could be held guilty of NLRA violations no matter the circumstances, but in New York and Porto Rico S.S. Co., 34 NLRB 1028 (1941), the Millis-led Board said the employer was absolved of guilt if it had been forced to act under union economic pressure. These and other critical decisions by the Millis Board were strongly approved of by Secretary of Labor Perkins and President Roosevelt. Not all changes at the NLRB deepened Millis' control of the Board. When Edwin S. Smith's term expired in August 1941, Millis wrote to Roosevelt and suggested William Hammatt Davis (Deputy Administrator of the NRA), attorney (and later Senator) Wayne Morse, Professor George W. Taylor, and economist Edwin E. Witte as Smith's replacement. Secretary Perkins suggested Gerard D. Reilly, a solicitor in the Department of Labor. Reilly won Roosevelt's approval. Reilly, however, was very conservative and adopted a legalistic approach to labor law, and Millis and many others at the NLRB considered him a reactionary. Reilly believed Millis was too much influenced by Chief Trial Examiner Frank Bloom (a left-wing lawyer) and Oscar Smith, head of Field Division. Millis thought Reilly's legalism interfered with "realistic" labor relations, and that he was too willing to impose his conservative views on national labor relations policy just as Madden and Smith had imposed their liberal views. Chairmanship during World War II The United States entered World War II on December 8, 1941, and the war significantly changed the NRLB and Millis' tenure as chairman. On January 12, 1942, President Roosevelt created the National War Labor Board (NWLB), whose existence displaced the NLRB as the main focus of federal labor relations for the duration of the war. The NWLB was given the authority to "finally determine" any labor dispute which threatened to interrupt war production, and to stabilize union wages and benefits during the war. Although Roosevelt instructed the NWLB not to intrude on jurisdiction exercised by the NLRB, the