CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE SIXTH CIRCUIT. No. 588. Argued March 5, 1942. Decided March 30, 1942. 1. The finding of the National Labor Relations Board that, by a supplementary oral contract between an employer and a labor union, it was agreed only that new employees would be required to join the union, was supported by substantial evidence. P. 690. 2. The conclusion of the Board that the closed-shop agreement between the employer and a labor union in this case was not valid