In the Universal Camera Corp. v. National Labor Relations Board case of 1950, the U.S Supreme Court ruled on how much deference courts should give to administrative agencies in their findings of fact. The dispute arose when an employee was fired from Universal Camera Corporation for union activities and complained to the National Labor Relations Board (NLRB). Initially, a trial examiner found that there were legitimate reasons for his dismissal unrelated to his union activities but NLRB disagreed with this finding and ordered reinstatement with back pay. On appeal, both lower federal courts sided with NLRB's decision. The Supreme Court however reversed these decisions stating that while substantial evidence is required on record as a whole including whatever in record fairly detracts from its weight; it does not mean that even as to matters not requiring expertise court may displace board’s choice between two fairly conflicting views although court would justifiably have made different choice had matter been before it de novo. This ruling established what has come to be known as "Universal Camera Test" which requires reviewing courts consider all relevant evidence rather than only looking at evidence supporting agency's decision thereby setting new standards for judicial review of labor disputes under Administrative Procedure Act.

In the dissenting opinion for Universal Camera Corp. v. National Labor Relations Board, Justice Frankfurter argued that the majority's decision to remand the case back to the Court of Appeals was unnecessary and could potentially undermine administrative expertise in favor of judicial intrusion. He contended that there was substantial evidence supporting NLRB’s findings against Universal Camera Corp., even when considering evidence contrary to these findings, as per Taft-Hartley Act amendments. The justice emphasized that courts should not overstep their boundaries by substituting their judgment for that of labor boards or other expert agencies unless there is a clear absence of substantial evidence on record supporting agency decisions. In his view, this approach would ensure respect for agency competence while still providing necessary legal oversight.