311 U.S. 514 (1941) Cited 241 times 1 Legal Analyses
In H.J. Heinz Co. v. N.L.R.B., 311 U.S. 514, 61 S.Ct. 320, 85 L.Ed. 309 and Cox v. Gatliff Coal Co., D.C., 59 F. Supp. 882, affirmed 6 Cir., 152 F.2d 52, it was stated that the Act contemplated that a collective bargaining agreement be in writing.
In Communication Workers of America v. Pacific Northwest Bell Tel. Co., 337 F.2d 455 (9th Cir. 1964), the earlier decision was adhered to. Cases reaching the opposite result, which apparently are in the majority, are collected at 337 F.2d at 458 n. 2.