Schechter Poultry Corp. v. United States
**Overview of Schechter Poultry Corp. v. United States**
Schechter Poultry Corp. v. United States is a landmark Supreme Court case decided in 1935 that examined the constitutionality of the National Industrial Recovery Act (NIRA) enacted during the Great Depression. The case arose when the Schechter Poultry Corporation was charged with violating labor regulations and selling unfit poultry under the provisions of the NIRA, which aimed to boost economic recovery by establishing fair competition codes. The Supreme Court unanimously ruled that the NIRA was unconstitutional, primarily because it involved an excessive delegation of legislative authority from Congress to the executive branch, resulting in vague regulations.
This decision is significant as it set a precedent for limiting Congress's ability to delegate its lawmaking powers, focusing on maintaining a clear separation of powers within the government. The Court's ruling emphasized the importance of defined legislative standards, declaring that such broad delegations could undermine accountability and governance. The case is often discussed alongside other important decisions that addressed similar issues of delegation, including Panama Refining Co. v. Ryan and Carter v. Carter Coal Co. Collectively, these cases reflect ongoing legal debates about the boundaries of federal authority and the implications of legislative vagueness during periods of economic crisis.
Schechter Poultry Corp. v. United States
Date: May 27, 1935
Citation: 295 U.S. 495
Issue: Delegation of power
Significance: Of the three Supreme Court cases voiding vague delegations of power to executive branch agencies, this ruling regarding the constitutionality of the National Industrial Recovery Act (1933) was the broadest.
The Schechter Poultry Corporation was charged with violating wage and hour provisions of the slaughterhouse industry and selling an “unfit chicken” under the 1933 National Industrial Recovery Act (NIRA). The act was designed to stimulate business recovery and end unemployment, largely through codes of fair competition and other regulations. The Supreme Court unanimously held that the NIRA was essentially unconstitutional because Congress delegated its lawmaking power to the executive branch through excessively vague legislation.
Schechter should be considered along with two other cases: Panama Refining Co. v. Ryan (1935) and Carter v. Carter Coal Co. (1936). In these three cases, the Court attempted to limit the later widespread congressional practice of transferring its lawmaking responsibility by delegating the hard decisions or the actual wording to executive branch agencies. In Schechter, the Court addressed the essence of the NIRA, unlike its narrow holding in the other cases. In his dissent in Panama, Justice Benjamin N. Cardozo argued that the national economic emergency of the Great Depression justified this vague delegation of power, but in Schechter he found that the delegation was so extensive that it had “run riot.”
Carter, the last Court decision attempting to limit vague delegations of congressional lawmaking power, was supported by only a 5-4 majority. The opinion, written by Justice George Sutherland, used the Tenth Amendment and the indirect-direct commerce distinction as an additional basis for rejecting the NIRA but ended up losing support on the Court. The four dissenters in Carter objected to this direct-indirect distinction. The Court never overturned its holdings in these cases but simply ignored them. Schechter is currently valid only on the narrow issues of the case.