National Labor Relations Board v. Cooper Tire & Rubber Co.

The subpoena enforcement statute for the National Labor Relations Board (“NLRB” or “Board”), 29 U.S.C. § 161(2), authorizes the Board to enforce its subpoenas in a jurisdiction in which its “inquiry is carried on,” which we have previously determined encompasses the location of an agency office investigating alleged wrongdoing. Here, that office is in the District of Columbia. The majority, however, concludes that Federal Election Commission v. Committee to Elect Lyndon La Rouche, 613 F.2d 849 (D.C.Cir.1979), contains a “clear requirement that an investigation must be nationwide in scope” in…