more than create a suspicion of the existence of the fact to be established. It is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, and it must be enough to justify, if the trial were to a jury, a refusal to direct a verdict when the conclusion sought to be drawn from it is one of fact for the jury. Associate Justice Hugo Black dissented, joined by Associate Justice Stanley Forman Reed. Black concluded that the majority had substituted its own appraisal of the evidence for that of the Board's, which was inappropriate. He also concluded that the majority disregarded the evidence that the mediators were negotiating with the employer on behalf of the union. {Cquote|To conclude that the company—through its president—was unaware the conciliators were acting at the instance of the Union, and therefore is not to be held responsible for its flat refusal to meet with its employees, is both to ignore the record and to shut our eyes to the realities of the conditions of modern industry and industrial strife." Black also noted that no arbitration was pending, and so the union was not in violation of its contract. Significance Initially, the Supreme Court had adopted the "mere scintilla" rule. As defined in Interstate Commerce Commission v. Union Pacific Railroad, 222 U.S. 541 (1912), the Court originally required administrative agencies to provide "more than a scintilla" of evidence. But by the late 1930s, the Court had shifted to the "substantial evidence rule." NLRB v. Columbian Enameling & Stamping Co. is the first significant, lengthy statement of this rule. But the "substantial evidence" test has been criticized as being "largely an exercise in semantics, i.e., an analysis of the words used in writing opinions and not of the extent in which reviewing courts inquired into the facts." The case was one of the first clear-cut defeats for the Board before the Supreme Court, after an unprecedented string of 15 successes. Along with NLRB v. Fansteel Metallurgical Corp., 306 U.S. 240 (1939) and NLRB v. Sands Manufacturing Co., 306 U.S. 332 (1939), the decision has been called one of the three most significant NLRB cases since NLRB v. Jones & Laughlin Steel Corporation, 301 U.S. 1 (1938) upheld the NLRA's constitutionality. The three cases also expanded the way the Court interpreted the NLRA. Although the justices had previously interpreted the Act solely