Administrative Law Breyer/AL.A. Schechter Poultry Corp. v. United States

From wikilawschool.org. Wiki Law School does not provide legal advice. For educational purposes only.

Facts: AL.A. Schechter Poultry Corp. was a poultry processing company that was charged with violating the National Industrial Recovery Act (NIRA) by selling "sick chickens" in violation of the "Code of Fair Competition" for the Live Poultry Industry of the Metropolitan Area in and about the City of New York. The company argued that the NIRA was an unconstitutional delegation of legislative power to the President and that the Code of Fair Competition was an unlawful exercise of the commerce power.

Procedural History: AL.A. Schechter Poultry Corp. was charged with violating the NIRA and the Code of Fair Competition in the United States District Court for the Eastern District of New York. The District Court dismissed the charges, holding that the NIRA was unconstitutional and that the Code of Fair Competition was an invalid regulation of intrastate commerce. The United States appealed the decision to the Supreme Court.

Issue: The main issue in this case was whether the NIRA was an unconstitutional delegation of legislative power to the President and whether the Code of Fair Competition was an unlawful exercise of the commerce power.

Holding: The Supreme Court agreed with the petitioner, holding that the NIRA was an unconstitutional delegation of legislative power to the President and that the Code of Fair Competition was an unlawful exercise of the commerce power. The Court found that the NIRA gave the President too much discretion to create and enforce codes of fair competition, and that the Code of Fair Competition was an invalid regulation of intrastate commerce.

Reasoning: In reaching its decision, the Court relied on the principle of nondelegation, which holds that Congress cannot delegate its legislative power to another branch of government or to private entities. The Court found that the NIRA gave the President too much discretion to create and enforce codes of fair competition, and that the Code of Fair Competition was an invalid regulation of intrastate commerce because it was not a proper exercise of the commerce power.

Comments: The decision in this case had significant implications for the New Deal and the role of the federal government in regulating interstate commerce. It also established the principle of nondelegation, which holds that Congress cannot delegate its legislative power to another branch of government or to private entities.