the chairman of the National Labor Relations Board. Appointment For more than two years, the NLRB had been under severe political pressure, and its chairman, J. Warren Madden, was seen as a political liability. The Board had issued three decisions (Fansteel Metallurgical, 5 NLRB 930 (1938); Inland Steel, 9 NLRB No. 73 (1938); and Republic Steel, 9 NLRB No. 33 (1938)) in 1938 which drew widespread condemnation from businesses and certain members of Congress. The Board won (In re Labor Board, 304 U.S. 486 (1938)) and then lost (Ford Motor Co. v. NLRB, 305 U.S. 364 (1939)) cases before the Supreme Court regarding its internal decision-making processes. And in three cases in 1939 (National Labor Relations Board v. Fansteel Metallurgical Corp., 306 U.S. 240 (1939); National Labor Relations Board v. Columbian Enameling & Stamping Co., 306 U.S. 292 (1939); and National Labor Relations Board v. Sands Manufacturing Co., 306 U.S. 332 (1939)) the Supreme Court emasculated the Board's attempts to expansively use Section 10(g) of the NLRA to promote collective bargaining and labor peace. Media and public opinion turned strongly against what was perceived as an overreaching NLRB, and President Roosevelt announced the formation of a commission to study the Board's operations. By March 1939, 11 bills had been filed in Congress to amend the NLRA. The House of Representatives voted to create a special committee, the Special Committee to Investigate the National Labor Relations Board (popularly known as the "Smith Committee" after its chairman, conservative Democratic Rep. Howard W. Smith), in July 1939. The Smith Committee was substantially biased against labor unions and the NLRB, received testimony from hundreds of witnesses, conducted a nationwide survey regarding the impact of the NLRB, and questioned NLRB officials at length about the agencies alleged anti-business and anti-American Federation of Labor/pro-Congress of Industrial Organizations biases. Nathan Witt, the Board's Secretary (and highest-ranking career official), was also under fire from the Smith Committee for his communist sympathies. The Smith Committee proposed legislation to substantially alter the NLRA. The legislation easily passed the House, but was bottled up by Roosevelt's allies in the Senate and it died. The dispute over the Board's administration had even split the NLRB itself. Board members William S. Leiserson and Edwin S. Smith were at loggerheads (Leiserson having accused Smith of being biased toward labor and the CIO in particular), and Leiserson threatened to quit if Madden was reappointed. The