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A.L.A. Schechter Poultry Corp. v. United States

(1935)

Supreme Court of the United States - 295 U.S. 495

tl;dr:

Congress’ delegation to the President of the power to approve codes of fair competition into law did not have an intelligible principle and was not a valid delegation of legislative power.

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Facts & HoldingA.L.A. Schechter Poultry Corp. v. United States case brief facts & holding

Facts:Congress enacted the National Industrial Recovery Act (NIRA) to enable...

Holding:Holding (Hughes): The intelligible principle rule dictates that Congressional delegations...

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A.L.A. Schechter Poultry Corp. v. United States | Case Brief DeepDive
Majority opinion, author: Me. Chief Justice Hughes
Level 1
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The case involves defendants who were convicted for violating the "Live Poultry Code," a code of fair competition for the live poultry industry in the metropolitan area in and around New York City. The defendants argued that the Code was unconstitutional and attempted to regulate intrastate transactions outside of Congress' authority. The Circuit Court of Appeals upheld most of the conviction but reversed two counts related to minimum wages and maximum hours of labor. The Supreme Court granted writs of certiorari for both the defendants and the government. The Live Poultry Code sets a maximum of 40 hours per week for employees, with some exceptions, and a minimum wage of 50 cents per hour. The Code prohibits the employment of anyone under 16 years old and guarantees the right to collective bargaining and freedom of choice regarding labor organizations. The Code is administered through an industry advisory committee and a code supervisor appointed by the Secretary of Agriculture and the Administrator for Industrial Recovery. The expenses of administration are to be shared proportionately by the members of the industry based on their volume of business or other factors deemed equitable by the advisory committee, subject to the approval of the Secretary and/or Administrator. The seventh article of the Code prohibits various practices that are considered unfair methods of competition. The final article requires verified reports to be submitted to protect consumers, competitors, employees, and others, and to determine the extent to which the Act's policy is being effectuated. Members of the industry must keep accurate financial records and submit weekly reports on prices and sales. The President approved the Code, finding that it complied with the pertinent provisions of the National Industrial Recovery Act and would tend to effectuate Congress's policy as declared in section 1 of Title I. The Secretary of Agriculture found that the Code's provisions establishing fair competition standards were reasonable regulations of interstate and/or foreign commerce and would tend to effectuate the policy declared in Title I of the Act. The Administrator for Industrial Recovery's report addressed labor provisions, including wages and hours of labor. The defendants are slaughterhouse operators who purchase live poultry from commission men in New York City or occasionally in Philadelphia. They buy the poultry for slaughter and resale at their wholesale poultry slaughterhouse markets in Brooklyn, New York City. The defendants' shochtim immediately slaughter the poultry prior to delivery. The defendants do not sell poultry in interstate commerce. Violation of any provision of an approved or prescribed code in any transaction affecting interstate or foreign commerce is a misdemeanor punishable by a fine of up to $500 per offense. However, the lower court erred in convicting the defendants for violating the minimum wage and maximum hours of labor provisions of the Code.

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Opinion (Concurrence), author: Me. Justice Caedozo
Level 1
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The legal case discusses the legality of delegating legislative power to the Executive branch. While prior rulings suggest that delegation is unlawful if it allows the delegate to decide on the necessity, time, and occasion of the act's performance, the author argues that the Executive should have limited discretion over the occasion but not the means. The case in question concerns a delegation that authorizes the delegate to investigate and correct any discovered issues. The article also discusses the legality of giving the President the authority to investigate and denounce "unfair" business practices in various industries. The author argues that this delegation is not illegal since Congress cannot legislate directly for every industry due to their diverse nature. However, the author suggests that a broader interpretation of codes of fair competition, which allows for a wide range of industrial regulations to be implemented, leads to an excessive delegation of power, which is not permissible under the law.

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