Imposed duty of fair representation on labor unions, requiring that they represent all members of their bargaining unit equally, without regard to race or union membership (later understood to include other protected categories, and eventually all misfeasance or malfeasance in the act of representing a member). Decided December 18, 1944 (argued 1944). Opinion of the Court: Harlan F. Stone → go there Topic: Discrimination based on race and ethnicity. Steele v. Louisville & Nashville Railway Co., 323 U.S. 192 (1944), is a United States Supreme Court case concerning U.S. labor law, specifically the responsibility of every formally recognized labor organization to equally represent all the members of their class or craft under the Fair Labor Standards Act (FLSA). The Court ruled that the Act covered employees regardless of whether they were members of duly recognized labor union, concluding that powers which Congress delegates to other organizations through statutes also delegates a duty to uphold the Constitution. Wiki link