In the 1939 case of National Labor Relations Board v. Bradford Dyeing Association, the U.S Supreme Court ruled in favor of the National Labor Relations Board (NLRB). The NLRB had accused Bradford Dyeing Association and other companies of unfair labor practices for refusing to bargain with a union that represented their employees. The companies argued they were not obligated to negotiate because some members of the union worked for more than one employer, which they claimed violated Section 8(1) and Section 9(a) of the National Labor Relations Act. However, Justice Felix Frankfurter rejected this argument on behalf of a unanimous court. He stated that there was no provision in these sections prohibiting multi-employer bargaining units or requiring an employee's undivided loyalty to one employer. Therefore, he concluded that employers could not refuse to negotiate with such unions under these circumstances.

In the dissenting opinion for the case of NATIONAL LABOR RELATIONS BOARD v. BRADFORD DYEING ASSOCIATION, Justice McReynolds argued that the National Labor Relations Board (NLRB) had overstepped its authority by ordering Bradford Dyeing Association to cease and desist from unfair labor practices. He believed that this was a matter for local authorities rather than federal intervention. According to him, it is not within NLRB's power or jurisdiction to force an employer into collective bargaining with a union if they do not wish to do so; such actions infringe upon employers' rights and freedoms under law. Furthermore, he expressed concern about potential abuse of power by NLRB in future cases if their decision were upheld in this instance.