In the case of National Labor Relations Board v. Lion Oil Co., the Supreme Court ruled in favor of the National Labor Relations Board (NLRB). The NLRB had found that Lion Oil Company was guilty of unfair labor practices by refusing to bargain with its employees' chosen representative, a union, about changes to an existing bonus plan. The company argued that it was not required to negotiate over this issue because it fell under their management rights clause in their contract with the union. However, the court held that while employers have a right to make unilateral decisions on certain business matters without consulting unions, they are still obligated under federal law (the Wagner Act) to discuss any changes affecting wages or working conditions. Therefore, Lion Oil's refusal constituted an unfair labor practice and violated workers’ collective bargaining rights.

In the dissenting opinion for the National Labor Relations Board v. Lion Oil Co. case, Justice Felix Frankfurter argued that the majority's decision to enforce a bargaining order was an overreach of judicial power and disregarded established legal principles. He contended that it was not within the court's authority to dictate specific terms of employment contracts or compel parties into agreement on such matters; rather, its role should be limited to ensuring fair negotiation processes between employers and employees under labor laws. Furthermore, he criticized the majority for failing to consider whether there were less intrusive means available before resorting to such drastic measures as enforcing a bargaining order. In his view, this approach undermined both employer autonomy and employee rights in collective bargaining negotiations by imposing predetermined outcomes instead of facilitating genuine dialogue and compromise.