Brown v. Hotel and Restaurant Employees, 468 U.S. 491 (1984), is a 4-to-3 ruling by the United States Supreme Court which held that a New Jersey state gaming law requiring union leaders to be of good moral character was not preempted by the National Labor Relations Act (NLRA). Background In 1976, New Jersey amended their state constitution to permit casino gambling in Atlantic City. On June 2, 1977, Governor Brendan Byrne signed the Casino Control Act (N.J. Stat. Ann. Section 5:12-1 et seq.) into law. The act established the New Jersey Casino Control Commission and instituted comprehensive regulation of casino gambling—including the regulation of labor unions representing gaming industry employees. In an attempt to forestall organized crime influence over labor unions, Sections 86 and 93 of the act imposed certain qualifications on officials of labor organizations representing casino industry workers. Among these qualifications were that the official be of "good moral character," not been convicted of certain felonies, and was not associated with organized crime. If a labor union's leaders did not meet these criteria, the union was prohibited from collecting or receiving dues from its members and from administering pension and welfare funds. Hotel Employees and Restaurant Employees Union Local 54 represented about 12,000 workers, 10,000 of whom were employed in Atlantic City casinos. Almost all of these casino workers had been organized since the legalization of gambling in the state. On May 13, 1981, the Casino Control Commission found that Frank Gerace, president of Local 54, and Frank Materio, the local's grievance manager, were associated with organized crime. The commission also ruled that Karlos LaSane, the union's business agent, was ineligible to be a union officer or agent because he had previously been convicted of extortion. The commission also found that union officers refused to cooperate with Casino Control Commission investigators, and held stock in Resorts International, Inc. (which owned one of the casinos in which Local 54 represented workers). Both actions contravened state regulations. The commission feared that Local 54 was being influenced by Nicodemo "Little Nicky" Scarfo, a reputed leader of the Scarfo organized crime "family" based in Philadelphia. National and state AFL–CIO officials, fearing the New Jersey law might open the door to extensive new state regulation of labor unions, asked Local 54 to test the New Jersey law in court. After a regulatory appeal, the Casino Control Commission unanimously rejected the union's contention that