[1] The Supreme Court overturned a ruling of the Board (requiring an employer to rehire striking workers) for not being based on substantial evidence.

Columbian Enameling & Stamping Co. manufactured metal utensils in Terre Haute, Indiana.

On February 14, 1936, the NLRB held Columbian Enameling & Stamping in violation of the NLRA for refusing to bargain in good faith with its workers, and ordered all strikebreakers fired and all former employees rehired.

As defined in Interstate Commerce Commission v. Union Pacific Railroad, 222 U.S. 541 (1912), the Court originally required administrative agencies to provide "more than a scintilla" of evidence.

[11] But the "substantial evidence" test has been criticized as being "largely an exercise in semantics, i.e., an analysis of the words used in writing opinions and not of the extent in which reviewing courts inquired into the facts.

Although the justices had previously interpreted the Act solely through the lens of the Commerce Clause (showing strong deference to the Board), now the Court evinced a willingness to apply evidentiary standards to the Board's actions and to impose a less radical interpretation on the law.