In the 1943 case of Polish National Alliance of the United States of North America v. National Labor Relations Board, the Supreme Court ruled in favor of the National Labor Relations Board (NLRB). The Polish National Alliance (PNA), a fraternal benefit society that provided insurance and other benefits to its members, had been charged by NLRB with unfair labor practices for refusing to bargain collectively with a union representing its employees. PNA argued it was not subject to provisions under Section 2(6) and Section 2(7) of the Wagner Act because it did not engage in commercial activities but instead operated as a non-profit organization providing services for its members. However, Justice Frank Murphy delivered an opinion stating that PNA's operations were indeed affecting commerce within meaning of those sections due to their substantial investments and business transactions across state lines. Therefore, they fell under jurisdictional reach of NLRB despite being classified as non-profit or fraternal organization.

In the dissenting opinion for Polish National Alliance of the United States of North America v. National Labor Relations Board, Justice Frank Murphy argued that the majority's decision to classify the Polish National Alliance (PNA) as a labor organization under Section 2(5) of the Wagner Act was incorrect. He contended that PNA is not an employer and its employees are not engaged in an industry affecting commerce, thus it should be exempt from this classification. Furthermore, he pointed out that PNA primarily functions as a fraternal benefit society providing insurance benefits to members and promoting Polish culture rather than engaging in any form of industrial activity or labor relations typical for organizations covered by Wagner Act provisions. Therefore, according to Justice Murphy’s interpretation, subjecting such entities like PNA to regulations designed for commercial industries would lead to unnecessary federal intrusion into their operations which could potentially undermine their cultural and social missions.