## Facts

- Virginian Railway Company operated as an interstate rail carrier employing shop craft workers in its mechanical department.
- After a failed 1922 strike, employees formed the Mechanical Department Association, which reached agreements with the Railway on pay, working conditions, and dispute settlement.
- Courts found the Association was substantially company-dominated, including Railway-funded expenses and Railway-issued election notices.
- The American Federation of Labor formed System Federation No. 40 in 1927 to represent the Railway’s shop craft employees.
- Following the 1934 amendments to the Railway Labor Act, a representation dispute was submitted to the National Mediation Board under § 2 Ninth.
- The National Mediation Board conducted an election and certified System Federation No. 40 as the authorized representative for the relevant craft/class.
- The Railway refused to recognize or negotiate with the Federation and continued dealing with the Association.
- The Federation sued in equity to compel recognition and to restrain interference with employees’ choice of representative and employer support of the Association.

## Issues

1. Whether § 2 Ninth of the Railway Labor Act creates a mandatory, judicially enforceable duty for a carrier to “treat with” the National Mediation Board–certified representative.
2. Whether the carrier must treat exclusively with the certified representative for collective bargaining and related purposes, rather than dealing with rival organizations.
3. Whether federal courts may grant mandatory and prohibitory injunctive relief to enforce the statutory duty and prevent employer interference.
4. Whether the statute and its enforcement exceed Congress’s Commerce Clause authority or violate the Fifth Amendment.

## Decision

- The Supreme Court affirmed the decree compelling the Railway to recognize and treat with System Federation No. 40 and restraining interference and support of the company-dominated association.
- The duty to “treat with” the certified representative was held mandatory, not merely advisory.
- The Act was construed to require the carrier to treat with the certified representative exclusively on matters within the representative’s statutory role.
- Injunctive relief was held available to enforce the statutory duties, even though courts cannot compel the parties to reach substantive agreement.
- The statutory provisions and their enforcement were upheld as constitutional under the Commerce Clause and consistent with the Fifth Amendment.

## Legal Principles

- Upon National Mediation Board certification under § 2 Ninth, a carrier has a mandatory duty to “treat with” the certified representative.
- “Treat with” requires meeting and conferring in good faith—listening to complaints and making reasonable efforts to resolve differences—but does not compel agreement or substantive concessions.
- The certified representative is the exclusive representative for collective bargaining purposes; carrier dealings with rival or employer-supported organizations in derogation of that representative violate the Act.
- Federal courts may enforce the Railway Labor Act’s representational and noninterference requirements through mandatory and prohibitory injunctions.
- Congress may regulate labor-relations procedures on interstate railroads to prevent commerce-disrupting disputes; requiring recognition and noninterference does not constitute a taking or deny due process.

## Conclusion

The Court held that the Railway Labor Act’s representation scheme obligates an interstate rail carrier to confer exclusively with the National Mediation Board–certified employee representative, permits equitable injunctions to enforce that obligation and prevent employer interference, and is a valid exercise of federal power consistent with the Fifth Amendment.


Virginian Ry. Co. v. Sys. Fed’n No. 40, 300 U.S. 515 (1937)