The Franks Bros. Co. v. National Labor Relations Board case in 1943 revolved around the issue of whether an employer was obligated to bargain with a labor union during a certification year, even if there were doubts about the union's majority status within that period. The Supreme Court ruled in favor of the National Labor Relations Board (NLRB), stating that employers must negotiate with certified unions throughout the entire certification year, regardless of any potential changes in employee support for said union during this time frame. This decision reinforced and clarified Section 9(c)(3) of the National Labor Relations Act which states that no election shall be directed by NLRB within one year after conducting a valid election; thus ensuring stability and continuity in collective bargaining relationships between employers and employees' representative organizations.

In the dissenting opinion for Franks Bros. Co. v. National Labor Relations Board, Justice Owen Roberts argued that the majority's decision to uphold a ruling by the NLRB was an overreach of federal power and violated states' rights under the Constitution. He contended that labor disputes should be resolved at state level unless they have a direct impact on interstate commerce, which he did not believe this case had demonstrated sufficiently. Furthermore, he criticized what he saw as an arbitrary distinction between "affecting" commerce and "burdening" it in order to justify federal intervention in local matters - something he believed was beyond Congress's constitutional authority.