Schultz v. N.L.R.B

In Schultz v. National Labor Relations Bd., 284 F.2d 254 (D.C. Cir. 1960), the court discussed the legislative history of 29 U.S.C. § 152(5), opining that the decision of Congress to omit the word "individual" from the definition of "labor organization" indicated a clear intention to exclude the individual from this broad definition altogether.