In the 1946 case of Bethlehem Steel Co. et al. v. New York State Labor Relations Board, the U.S Supreme Court ruled in favor of the state labor board, upholding its jurisdiction over a labor dispute at a shipyard during World War II despite federal wartime control over production and wages at such facilities. The court held that although Congress had given certain powers to federal agencies for war purposes, it did not intend to strip states of their traditional authority over local industrial relations unless there was clear evidence showing this intention or if state law conflicted with federal law or policy objectives. In this case, no such conflict existed as both levels sought to prevent work stoppages that could hinder war efforts; therefore, New York's enforcement of its own laws regarding collective bargaining rights didn't interfere with any national defense needs managed by the Federal government.

In the dissenting opinion for Bethlehem Steel Co. et al. v. New York State Labor Relations Board, Justice Frankfurter argued that the majority's decision to uphold state labor laws in this case was inconsistent with previous rulings where federal law had been deemed supreme over state regulations in matters of interstate commerce and labor relations. He believed that by allowing states to enforce their own labor laws on businesses involved in interstate commerce, it would create a patchwork of different rules and regulations across the country which could potentially disrupt trade and economic stability. Furthermore, he contended that such an approach undermines Congress' authority under the Commerce Clause to regulate these areas uniformly at a national level.