National Labor Relations Board v. Bell Aerospace Company Division of Textron Inc.

A union sought to organize buyers at Bell Aerospace's (plaintiff) plant, and Bell argued the buyers were exempt "managerial employees" under the National Labor Relations Act. Litigating the issue, the NLRB (defendant) reversed its earlier blanket managerial-employee exemption, adopting a narrower rule exempting only managers with labor-management responsibilities, and found Bell's buyers lacked such responsibilities and were covered by the Act; a federal appellate court held the Board could reach this result only through rulemaking, not adjudication, and the Supreme Court granted review.