Statement Opposing Jurisdiction — La Crosse Telephone Corp. v. Wisconsin Employment Relations Board

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"SUPREME ¢ C ouRr, ug ae |

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po: SUPREME COURT OF THE UNITED STATES 0 2

f ' OCTOBER TERM, woe” Sean) ,

to iA S So

_{EA CROSSE THLE PHONES € CORPOR ATION,

cual Appellant,

“vs.

“WISCONSIN EMPLOY MENT RELATIONS | BOARD, .

Pe hi | ET AL. 7" |

INTERNATION: ALB ROTHERHOOD. OF ELEC "TRICAL

- WS aed WORKERS, LOCAL B-953, A. F. OF L,,

~ es | ” oe. -- “Appellant, |

WISCONSIN EMPLOYMENT RELATIONS BOARD,

; ET AL.

APPEALS FROM THE SUPREME COURT OF THE STATE OF WISCONSYN

STATEMENT OPPOSING JURISDICTION

Jounx FE. Martin,

Attorney General;

. Stewart G. Honeck, —

Deputy Attorney General;

Beatricy LAMPERT,

Assistant Attorney Gereral,

Counsel for Appelices.

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ao | Sivesscr INDEX ee. _

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- Statement opposing: jurtediotion Pic dttal : ou bode e 4

Nature of decision of Wisconsin Supreme peers ;

Wo crs ca, AES phe yh ge) beeches ae

GME <6 52 ake ex's NDS bes fe ae os a ae

TABLE OF Cases. TED —

got hele State Federateon. of Labor v. ‘McAdory, 325

U.S. 450, 65 Sup. Ct. 1384, 89 Ae Bal. 1726... ts 6,7

Allen-Bradley Local 1111 v. Wisconsin’E. R. Board, .

315 U.S. 740, 62 Sup. Ct. 820; 86 L. Ed. 1154.....- ae

'.. American Federation of Labor v. National L. R. a A

Board, 308 U.S. 401, 60 Sup. Ct. 300, 84 L. Ed-347.. - 8 |

Bourgeois Vv. Fairchild, 33 So. 495, 81. Miss. —:.. 10

; ; eet v. Maxwell, 38 S. EK. (2ay 176, 73 Ga. App...

NBS eee ac CH are Wao ge Cert Bat a ek ae Cr ar ne

pete é N. W. R. Co. v. Hitirood Commission, —— ae i

156 Wis. 47, 145 N. W. 216.0273)... ae .§

Hotel & R. E.1. Alliance v. Wis.

437, 62 Sup. Ct. 706, 86 L. Ed. 94

Faitoute Iron & Steel Co. v. Asbury Park, Soe U. Ss.

502, 62 Sup. Ct. 1129, 86 Li. Ed. ny eee. Tea AN

OE So thw ae 19

.. People ex rel. Griffith v. Bundy, 409 (2a) 261, 1 a ea

i: Colo. 102...... SE, oh DEMS ty hen Mery 40°

_ Pulliam v. Christian, 47 U.S. 209, 6 How. 209, 12 Le eae

ok a i oe aD

, "Re ~ddall vy. Bryan, 65-0. S. 420, 24 How. 420, 16 L. Ea. Pichi

UME rd eta Sacks cod Chee ken See eee 7,9

State ex inf. Anderson, ex rel. Booth v. Moss, 172 S. | 7 Ra

W. 1180, 187 Mo. App..151 . ees -10

e-

ii INDEX

: é ; : Page

| State ex rrel. Caldwe lly. McQueen, 159 S. Ww. ( (a) 436,-

178 Tenn. 478... . ~ 10

State ex rel. Donnell vy. Osbuan, 147 S. W. (2a) 1065, - :

347 Mo. 469, 136 AJL. R. 667... (10

Stevens v. Jones, 123 N. W. 705, 248. D. 97, ie.a> eee

‘United R: d W. D.S. E. of A. v. Wise onsin E.R, |

Board, 245 Wis. 636,15 N. W. (2d) 844.0002. a

Voeller v, Neilston Warehouse Co., 311 U.S. (9531, 61 |

Sup. galerie Tape haat coun tesa he

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“IN SUPREME COURT, STATE. OF WISCONSIN’

AvovsrsTenm, 1947

mee HOE, eee

LA CROSSE TELEPHONE CORPORATION, aoe |

Petitioner oui Re spondent, ae 8

a ot eee Oo ean eae

—

=

WISCONSIN EMPLOYMENT’ RELATIONS | BOARD,

LL. E: GOODING, HENRY RULE, anpJ. E. FITZGIB- ;

BON, | ve =

aie Defendants and. wad Appellants

‘IN TERNATIONAL BROTHERHOOD OF ELECTRICAL: és

an LOCAL B-953, A. F. OF L., oe

wert, 7 Petitioner a Respondent, ee Uy

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,

WISCONSIN EMPLOYMENT RELATIONS BOARD, 7

L. E. GOODING, HRNRY RULE, anv J. E. RITZGIB- |

BON as MEMBERS OF THE . - Leasteiesioaar EMPLOYMENT

_ RELATIONS BOARD, oe

Defendants and Appellams is

7 STATEMENT OF APPELLEE AGAIN ST J URISDIC- Z

TION OF THE SUPREME COURT OF THE UNITED

— , ae

a Nature of Decision of Wisconsin bikes Court -

The appellants’ statements as to jurisdi¢tion have not _

fully and accurately described the nature of the riling of :

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the Wisconsin Supreme Court from which appe: ul is s taken,

nor the nature of the contentions made by the appellée |

before: the tte court. The Wi isconsin’ Supreme * Court

reversed a-dec

that ‘the. Wi isconsin Employment Relations Board .wa

precluded by the constitution from condticting an slestign

‘to determine desires of employces Sof a local telephone cor-

poration with respect toa collective bargaining representa-

* tive by ven-though the National Labor Relations Board had |

éver taken any‘ action involving the compaity or its

aa

Cori toyten, and even though ‘the election did not com rayvene

“any substantive provision of the National Labor: ‘ReJations

Act nor, any policy ‘fixed by the National Labor Relations

Board.” In submitting to'the state supreme court the i issue.

"a .

‘of whether such ealing was cor rect, fhe — asked : °,

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“Does the National ‘Labor: Relations _Xet preclude

tlre Wisconsin Employment Relation’ Soard frda con-

“k ducting an election to determine the desires of em-

ployees of a loca] telephone corporation: with respect to

a collective bargaining repfesentativ e, irrespective of

taken any action involving the company and its eme

, ployees, ‘and: irrespective 6f whether the’action of the

state board contravenes ‘any substantive provisions ‘of -

. the national’ act or. any fixed policy of the national

—

s

It was not suintanclas by the appellee (because it Was. not

necessary, for purposes of his case), nor was it held by the

state supreme ‘court that the question could ‘or should be

answered with an unqualified negative. Thé supreme court’

decided, in acco ordance with the appellee’ 8 contentions, that

the “question could not be answered with an unqualified ~

affirmative as the ,trial court had done. The gist ofthe |

Wisconsin Supreme Court’s decision i is.that the state-board

| not precluded’ from conducting . an election among em-

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whether the Nationnl Labor Relations: Board has ever

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n of a lower court, which was to the —

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ployees of a ‘loeat félephone. company - -to determine their

desires. as fo a bargaining agent-w hen, the National Labor

Re ati ions Board has hever taken any jurisdiction whatever

of the relations between the employ er and itsemploy ees and

when there is no showing of -confhet with, provisions, or

pélicies of the national att. ©:

«

-

Bon ae Facts* . : ye

| + the Suprerhe. Court of the u ted States pointed out

in Allen-Bradley ‘Loc al 1111. Vv. Wisconsin, FE. R, Board >

(19424, 31% U.S. 740, 746-747, 62 S. Ct. .820, 86 L. Ed. 1154,

it is not. concerned’ with theoretical disputes or anticipated

controversies, but with specific i issues; and soit confines its.

consideration te-the pr ecisé facts @f the cs ase before it rather

--than to attempt adjndic: ition Of the atidity of other types:

of action which might arisé in other case§: The courtethere

said that it was ‘not under the necessity -of treating, the

state Act ds am ingeparable whole?’ : but for purposes,of a

particular ¢ ‘ase must read the state act ‘‘as. though it con-

_tdined only those provisions * which authorize the state

take. *

Board”’ to take the ‘particular type of action which it did

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;

Under the foregoing. rule, the facts. which inust be con-

_ sidered are: ‘

The Telephoiic Guild of Wi iséonsin (hereinafter enter red

to as the Guild) petitioned, the Wi isconsin Employment Rela-

tions Board (hereinafter refer ‘od to as the State Board)

to conduct tan election to determine the desires ofemployees

of the La C rosse Telephone Cor poration. (hereinafter refer:

cred to as thie Company or the Employer) as to a bargaining.

_tepresentative. The. State Board. conducted an investiga-

tion, including a hearing, to determine whether ‘the cir-

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7 Page references are to the reeord and . hefo he Wisconsin

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cumstances warranted invocation of its services, although

such'preliminary hearing find i inv estigation are not expressly ;

required by state statute. :

“The Company had been bargaining fora number of years

previdusly with the Intérnatioy ‘Brotherhood ‘of Electric al

. Workers, Local B-953, A. F. of L. (hereittafter referred to

as Local B-953) on behalf of cael A Y in its plant and

. traffic departments.

After the hearing the State Board conducted an electio ion

among all the Company’s eniployees, in which the plant

and traffic department employees voted to bargain together

as in the past, and voted overwhelmingly in favor of the.

Guild as a bargaining representative. (The vote in favor

«.. of the’ Guild was 91-against and only 14 for Local B-953)

q

(R. 61, pp. 32-34; A-Ap..121-124). The Board entereg no

- arder, but certified. as a fact. the fesults of this election.

The National Labor Relations Board has never at any

time taken any jurisdiction with respect. to either the

Company or its employees. It has made no finding ,that

any unfair practice or question of representation arising

between such employer and its ‘employ ees affects commerce.

There has been’ no conflict in the application, of the

Wisconsin ‘law with either-a substantive provision of an

‘act of Congress or any policy formed de the National

. Labor Relations Board. - dsp ey a

The State’ Board did not, attempt to” chneler any ‘dis- ~

cretion respecting the bargaining unit, but merely, .con-.

*aucted a. vote to ascertain the wishes of the employees.

The bargaining unit selected by the employees is entirely -

‘consistent with provisions of the national law. and with |

policies followed by the National Board thereunder. (If

there are any provisions of the Wisconsin statutes which

might be applied, as to-wholly intrastate enterprises, in

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a manner different from an in which the National Act

might be applied, the State Act makes: provisigs under sec,

111.17 for severabiltly so that provisions of the*law which

cannot be applied in a particular cise do not prevent the

application of other portions of the, state, law.).

The employer. is a Wisconsin corporation, all of whose

employees work withit the boundaries of the state. It?

primary function is to operate a Jocal telephone service.

“*There is nothing in the ‘record. made before the State

Board to indicate that the Company engages in interstate

service, Allegations to that effect were made in the petition

for review, but allegations of fact'in the petition for review

are not part of the record which may be- considered” by

state. courts. upon, revipw. The only ev idence relating to

the source. of the company’s revenues which is Hroperly in

the record arose in the Supreme Court when the State.

Board called. the attention’ of the Court (in accordance

- with the rules of judicial notice applicable in the state -

as illustrated in Chicé ago & N. W: R. Co. v. Railyead-€ om-" .

mission, (1914) 156 Wis. 47, 145 N. W. 216, 974) to the

last annual, report filed by the employer with the Stat

Public Service Corjission, stating under, oath that all °

of. the employer’s revenue was derived from intrastate

service. - The mere’ fact that the Company is ‘subject to

regulation hy the State Publie. Service Commission dem- °

‘onstrates that it conducts an intrastate serv ige. of great

importance to the people within’ the state.

°We. have no doubt that it also participafgs to some .

‘extent ing interstate toll communication service although=

the extent of interstate. commerce is to. be proven rather

than presumied, since its regulation. lies in a delegated

field. Whéther the extent of ‘interstate service of a pri-—

piarily intrastate enterprisg: 4is sufficient to warrant the

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finding necessary ‘to assumption of jurisdiction by. the Na- ~

' tional Board under the National Act is a questign of fact

which that Beard, must determine in each case. That- is,

where a question ‘of representation does not actually arise.

in commerce, the National ‘Board must determine as a fact

whether it id of such. moment that ‘it threatens to obstruct

commerce. As the Wisconsin Supreme Court has pointed

out in its decision in the instant case, the National Board

is not required to accept ‘jurisdiction ’or exercise its ‘powers

“on every petition or complaint filed with it because “Not.

~ every labor dispute:arises to sugh dignity that it impedes’

. and obstruets intérstate commerce’ although the employer

may be engaged in what has been. defined as interstate |

%9

That proposition is. well illustrated in this

‘ase. The National\. Board. did not ‘take jurisdiction of

the? petition for election filed with ét, and’ so it’ has never

made the Ginling necessary to. rian application of the

National Act. |

As this Court pointed out in Alabama State Fede ration

commerce,

of Labor v. McAdory, (1945) 325 U.S, 450, 464, 65 8. Ct.

1384, &9 L. Ed. 1725: : te

iia aD The National Labar sae Act does not

extend to all industries and all employees, It is only

-applicable to those employments in which strikes and

labor disputes would affect interstate ‘commerce anid -

-are found to be such bythe National Labor Relations

Board, = ee supplied )p 6

The fact in this case is that, neither the National Labor

Relations: Act nor its successor has ever. been applied to —

relations of the employer and employees ‘here involved;

and the National Board has never made any finding neces-_

sary to the application of those acts.

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Argument

While it is the strong. cony iction of the appellee that the

action here invelved,. even if: it were legally” enforcible,..

would not interferé with Congressional regulation of in-.

terstate cammerce nor: infringe upon any constitutional

rights, we will not argue the merits of that ‘position at

- this time. This argument will be restr icted.to jnrisdictional,

points. Appeal will not lie-in Ahis case for two reasons =

(1) The action appéaled from is not a‘final judgment in

_ the sense of making a final disposition of the rights of the

patties. (2) The parties aerane appeal are not adversely

affected by the action. ae ; i

It requires no citation of authority to sermon the prop- a3

osition that only final det terminations are appealable to

the United States Supreme Court. A merely practical

order preparatory to a final hearing, by whieh the rights

of the parties are not affect ted, is not .a- final order so as

to-be appealable. Pulliam v. Christian, (1848y 47 U.S. 209,

6 Howard 209, 12 L. Ed. "409. Whe re the decree involved

is merély interlocutory i in nature no appeal, will lie to the

United States Supreme ( ‘ourt even though state laws allow

it to be appealed to the state appellate courts. -Reddall v.

~ Bryan, (1860) 65 U, S. 420, 24 Howard 420, 16 L. Ed, 740.

_In support of the other j Jurisdictional proposition involved -

we cite Alabama State Federation of Labor v® McAdory,

(1945) 325 U.S. 450, 463, 65 S.-Ct. 1384, 89 L. Ed. 1725, i in

which ~ United States Supreme Court said :

ue be Only those to whom a statute! applies and

who are adve rsely affected by it-ean draw in question

its constitutional validity in a declaratory judgment.

proceeding as in ‘any other. aa (Emphasis sup--

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SI mm AI mn I SER SR SAI RMI SS NS oN A | oT

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The court also sata} in Vv ‘oeller v. Neilston Ww atehou seC 0.,

(1941) 311 U.S, 531, 537, 64 8. Ct. 376, 85 La Ed. 399 ;

oe * * Pyercising ay very delicate responsibility

of passing upon , the validity of state statutes, this

Court has m many times declared the rule that only those

who have been injured as the result of the denial of

‘constitutional rights can invoke’ our jurisdiction on

constitutional questions. wii ees

Doubtless these rules arise from the fundamental. prop-

-osition enunciated in Faitoute Iron € Steel Co. v. Ashbury

Park, (1942) 316 U.S. 502, 62 S. Ct. 1129, 86 I. Ed. 1629,

that the: constitution was ‘f ‘intended ‘to preserve practical

- and substantial rights, not to maintain theories.’ ?’

In determining thé nature of the action of which review

is sought by the United States Supreme Court, We must

look to the construction placed upon it. by the supreme

“court of the state- As pointed out in Hotel € R. KE. I. Alli-

ance Vv. Wis. FE. R. Board, (1942) 315 US. 437, 440, 62

S. Ct. 706, 86 L. Ed. 946, the — of the restraints,

if arly, imposed upon-the parties ‘‘is for the Wisconsin _

Supreme Court to determine.’’ The legal effect of the.

certification by the State Board of the results of an election.

‘conducted by it was termed by the State Court as ‘mere.

fact-finding procedure.”’ No one can be aggrieved ® the ~

legal sense by a mere . finding of facet which has no 20m

_pulsory effect. : Se

This viewpoint aceords with the rulings of the Federal

courts respecting certifications of the results of¢elections

made. by the National Board: Such certifications under the

National Labor Relations Act were not even ‘reviewable, |

American Federation of Labor v. National L. R: ‘Board

(1940), 308 U.S. 401, 60 S. Ct. 300, 305, 84 L. Ed. 347. “While

similar action. of the State Board is made = iewable in

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Wisconsin courts, ‘that is the result of legislative poliey

‘rather than of: constitutional, necessity. As pointed out in

Reddall v. Byran (1860), 65 | »S. 420, 24 Howard 420, 16 L.

Ex. 748, a statute making ac tion reviewable in state courts

_ has no effect upon. the jurisdiction of the F ederal courts,

’ Federal,courts have regularly held that elections and ~

certification procéedings by the National Board are of ¢

nonadv ersary, factHinding | character. See, ‘for nile

the cases cited-in United R. & WD. S.E. of Ay. Wisconsin

E.R. spirit Un 245 Wis. 636, 641,15 N. W. 2d 844: |

wee To the acts of the board in ordering and

Renee and certifying theeresult of a referendum

there is applicable, xi analogy, the court’s statement in

> Southern SoS. Co. : National Labor Relations Board :

(3d Cir), 120 Fed. ( 2d) 905, 506—

& ***A certification proc ceding -is of a nonadversary,

fact-finding character in which the board plays the part

of a disinterested investigator seeking mere ‘ly to ascer-

tain the desirés of the employees as-to their rapeinenia-

tions’

“See also National Labor Re Mibiocs Board vy. Botany

. . Worsted Mills (3d. Cir.), 133 Fed. (2d) 876, 882, in

f respect to an inv estigation preliminary to an election,

* to wit:

‘* «The preliminary investigation and-the hearing in

- the. representation proeeeding are not ‘contentious

litigation ; not even litigation, ' but investigation.’ ”’

.

The State Board’s action was ministerial in charaeter,

somewhat similar to the action of general election officials

who conduct elections and, canvass their results. Sueh fune:

tions do not involve an exercise of discretion on the part of

the officials. See, for instance: ee oles

Brocke I v. Qarwell (1946), 38 S. E. 2d. 176, 108, 73 Ga:

_ App. 6638; :

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Bourgec o1s-V. Pairchiia (1903), 33 So. a, 496, 81 Miss.

708 ;. :

_° State ex “inf, hides ex rel. ‘Booth v. Moss ( ‘191: »,

"172 SW. 1180, 1181, 187 Mo. App. 151;

. State ex rel. Caldwell v. McQueen (1942), 159 S.W. mI

436, 438, 178 Tenn. 478 ; ee

People ex rel. Griffith v. Bundy (1941), 109 P. od 261,

- 263, 264, 107 Colo. 102;

State ex rel. Donnell v, Osburn (1941), 147 S.W. 2d

1065, 1068, , 1069, 347 Mo. 469, 136 A.L.R. 667. :

3) /

The Wisconsin Supreme Court: has pointed out that the

—: State Board’s action which is under consideration on.these

‘appeals does not involve the exercise of its discretion nor -

the formulation of any policy which does or could vary

from those of the National Labor Relations Act:

/ .

“The mere fact- finding procedure of. the slate board

in the ascertainment. of facts, and its thereupon order-

ing and conducting an election-and-certifyi ing the result

~ thereof constitutes an action in merély’ its ministerial

jinaetiy.* > = °” :

The appellants urge that the board’s action was not min-

isterial because it made a determination of the status of-a

contract between the employer and Local B-953, during its

- investigation to detérmine whether an election should ‘be

held. It exercised no discretion in making such a deter.

mirmtion, since it was obligated to apply the rules. of law

preyailing in this state. Such rules, according to Ogden v.

Saunders, 25-U. 8.213, 12 Wheat. 213, 6 L.Ed. 606, neces-

sarily govern the nature, requisites and validity of a con- |

. tract mgde i in this state. The board correctly applied such.

rales, as is demonstrated by the decision of the Wisconsin,

‘Supreme Court. It was pointed out in Stevens v. Jones

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(1909), 1: 23 N. W. 705, 708, * 24 S. D. 97, that an action is ho.

less ministerial because the person obtigated. to pérform tho -

act must first satisfy himself of the « e xistence of the state of

facts upon wliich the duty arises e a 5 eee.

The certification of ‘the cdsults of 4 an ‘lection conducted

- by the:state board is merely, the furnishing of information

to parties ‘who are presumably interested. The ‘now ledge

of such facts should assist them i in their negotiations.

The ‘certification is not-made legally enforcible, perhaps

for the reason that in at least nine cases out of ten no en-.)

forcement is needed. When parties know the facts, they

“an act ac¢ordingly, The certification serves only the pur-

pose of acquainting | them with the facts. ;

Before anytegally enforcible action could be taketh on n the

basis of A’ certification of the results of an election, adidi-

‘tional proceeditigs would be necessary with\the usual con-

comitants of notice, and hearing. The certification of the

fact of the employ ee’s wishes, therefore, i is nothing more

than an intermediate step without legal force. "he

The appéllants have not shown, nor could they, show,

that they have’been prejudiced or adversely affected by the

certification. Although the certification was issued Janu--

“ary. 14, 1947, the appellants have ever since refused‘to

recognize 1 without any adverse effect upon themselves.

(No stay of execution was applied for or issued bevause.

no enforcement is: possible.) Surely that fact in itself

_ demonstrates that the appellants could not be prejudiced

by a mere certification of the results of iin election ‘among

the employ ees. If the knowledge of the desires of the em. ~

ployees ‘has prejudiced the employer and the rejected or-

ganization, the prejudic@is surely not to their constitutional

crights. -If anyone has Deen déprived of constitutional

rights, 1 rights sought to be protected by Federal legis sta-

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; tion, it lias not been the appellants but the 91 eniplay ees

: whose choiee of an agent has wre frustrated: by them, coon |

Respec'filly submitted, - ae |

i wage OS eat Sarre Jone E. Martin,

EV ion poe ne ee ee Attorney General,

| Sie ea. Stewart G. Honecx;

| Deputy Attorney General

Beatrice Lampert

Assistant Attorney General

5 Attorneys for Wisconsin Em-

; : ployment Relations Board

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