The U.S. Supreme Court case National Labor Relations Board v. Indiana & Michigan Electric Co., et al., 1942, revolved around the issue of whether an employer's refusal to bargain with a union could be considered as unfair labor practices under the National Labor Relations Act (NLRA). The company had refused to negotiate with its employees' chosen representative on grounds that it was not their exclusive bargaining agent and some employees were coerced into joining the union. However, the court ruled in favor of the National Labor Relations Board (NLRB), stating that once a majority of workers have selected a representative for collective bargaining purposes, employers are obligated by law to negotiate in good faith with this representative regardless if all workers belong or support said union. The court also found no substantial evidence supporting claims about coercion used by unions during membership drives.

The dissenting opinion in the case of NATIONAL LABOR RELATIONS BOARD v. INDIANA & MICHIGAN ELECTRIC CO. et al., 1942, argued that the majority's decision to uphold the National Labor Relations Board's (NLRB) order was incorrect because it failed to consider whether or not Indiana & Michigan Electric Co.'s actions were motivated by anti-union sentiment. The dissenters believed that there was insufficient evidence presented by NLRB proving that the company had engaged in unfair labor practices as defined under Section 8(1) and Section 8(3) of the National Labor Relations Act, which prohibit employers from interfering with employees' rights to form unions and discriminate against employees for union involvement respectively. They contended that without clear proof of such motivations, it is unjustifiable to impose sanctions on an employer based solely on their decisions regarding employee relations.