In re Labor Board, 304 U.S. 486 (1938), is a 5-to-2 decision by the Supreme Court of the United States which held that the National Labor Relations Act requires the filing of a petition and a transcript in order for an enforcement order to proceed in federal court, and that a writ of prohibition and writ of mandamus are appropriate measures to take in quashing a petition when no transcript has been filed. Background After the passage of the National Labor Relations Act (NLRA) in 1935, the National Labor Relations Board (NLRB) found itself attempting to enforce the law against hundreds of employers, most of whom refused to acknowledge the constitutionality of the NLRA or obey the Board's orders. The Board's practice was to have its Economic Division study the issues and report to the Board; order its attorneys in its Review Division to analyze the case and report to the Board; review the transcripts of the field office trial de novo; receive an oral report about the case from the trial examiner; and have the Chief Counsel's staff prepare a draft decision for Board consideration. But in Morgan v. United States, 298 U.S. 468 (1936) and Morgan v. United States, 304 U.S. 1 (1938), the Supreme Court held that parties in quasi-judicial hearings before the government had the right to be presented with the issues the government was considering, present the agency with a statement, review the proposed findings, review any tentative reports, and submit exceptions and argument to the agency before a final determination is made. The Steel Workers Organizing Committee (SWOC), a union affiliated with the Congress of Industrial Organizations, had attempted to organize the plants of Republic Steel for several years. On May 26, 1937, members of SWOC to strike Republic Steel. The strike soon spread to Bethlehem Steel, Inland Steel, Jones and Laughlin Steel Company, and Youngstown Sheet and Tube—the so-called "Little Steel" group (because each company was smaller than the giant U.S. Steel). The Little Steel Strike became one of the most famous in American history. Violence quickly engulfed many of the strikes, with both side employing violence. On May 30, 1937, members of the Chicago Police Department shot and killed 10 unarmed union demonstrators near the Republic Steel plant in Chicago in what later became known as the Memorial Day massacre. However, almost 200 SWOC members pleaded guilty to various felony charges (possession