NLRB v. Jones and Laughlin Steel Corp.

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In NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1 (1937), the U.S. Supreme Court upheld the National Labor Relations Act against a Commerce Clause challenge, and in the process, departed from the distinction between "direct" and "indirect" effects on interstate commerce. Id. at 36-38 ("The question [of the scope of Congress' power] is necessarily one of degree").

The Court held that intrastate activities that "have such a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens and obstructions" are within Congress' power to regulate. Id. at 37.