Humphrey’s Executor v. United States
Humphrey’s Executor v. United States is a significant Supreme Court case that addresses the limits of presidential power regarding the removal of officials from independent regulatory agencies. In this case, William Humphrey was removed from his position on the Federal Trade Commission (FTC) by President Franklin D. Roosevelt, who aimed to appoint someone who supported his New Deal policies. The FTC Act restricted the president's ability to dismiss commissioners to instances of inefficiency, malfeasance, or neglect of duty, leading to a legal challenge after Humphrey's dismissal.
In a unanimous decision, the Court ruled that Roosevelt had exceeded his authority, emphasizing that Congress had the right to establish independent agencies with specific functions that could operate without executive interference. The Court's opinion clarified that the president's power to remove officials applies primarily to those engaged in purely executive roles, thereby protecting the integrity and independence of regulatory agencies. This ruling effectively narrowed the precedent set by Myers v. United States, which had suggested broader presidential removal powers. The implications of this decision continue to influence discussions on the balance of power between the presidency and independent regulatory bodies, highlighting the importance of legislative intent in defining the roles and protections of such officials.
Humphrey’s Executor v. United States
Date: May 27, 1935
Citation: 295 U.S. 602
Issues: Presidential powers; separation of powers
Significance: The Supreme Court ruled that the president could not remove members of independent regulatory commissions on policy grounds before their terms had expired.
In Myers v. United States (1926), the Supreme Court upheld the authority of the president to remove a postmaster before his term had expired. A dictum (statement of opinion or belief) in the opinion suggested that the president would also have power to remove officials within the independent regulatory agencies. William Humphrey, a conservative Republican, was appointed in 1931 to serve a seven-year term on the Federal Trade Commission (FTC). The FTC Act authorized the president to remove a commissioner only for inefficiency, malfeasance, or neglect of duty. Nevertheless, when Franklin D. Roosevelt became president, he fired Humphrey in order to replace him with a supporter of New Deal policies.
By a 9-0 vote, the Court held that Roosevelt had exceeded his powers. Justice George Sutherland’s opinion for the Court reasoned that Congress possessed the authority to create regulatory agencies with quasi-legislative and quasi-judicial functions, designed to act independently of executive interference. That authority included the power to fix a term of office because the commissioners could not act independently if they served at the pleasure of the president. The ruling narrowed the Myers precedent so that the president had only “the unrestrictable power” to remove executive officials performing purely executive functions.
Although controversial at the time, the Humphrey’s Executor decision remains good law. In Wiener v. United States (1958), the Court held that the president could not remove a member of a regulatory commission unless explicitly authorized by Congress.