The U.S. Supreme Court case National Labor Relations Board v. Metropolitan Life Insurance Co., 1964, centered on the issue of whether an employer's refusal to bargain with a union over changes in company-wide employee benefits constituted unfair labor practices under the National Labor Relations Act (NLRA). The court ruled that it did constitute such practices and upheld the decision of the NLRB, which had found Metropolitan guilty of violating sections 8(a)(1) and 8(a)(5) of NLRA by unilaterally changing its nationwide hospitalization plan without bargaining with unions representing its employees at different locations. The court held that even though these were company-wide policies affecting both unionized and non-unionized workers, they still fell within "conditions of employment" subject to mandatory collective bargaining under NLRA because they affected wages, hours or other terms or conditions for employment.

In the dissenting opinion for the National Labor Relations Board v. Metropolitan Life Insurance Co., Justice Harlan disagreed with the majority's interpretation of Section 8(a)(1) of the National Labor Relations Act, which prohibits employers from interfering with employees' rights to form, join or assist labor organizations. He argued that an employer should be able to express its views about unionization as long as it does not threaten reprisals or promise benefits in a bid to influence employee choice. In this case, he believed that Metropolitan Life Insurance Company was merely expressing its preference for dealing directly with employees rather than through unions and did not violate any law by doing so. Furthermore, he contended that there was no substantial evidence showing that such expression had a coercive effect on employees' decision-making regarding union membership.