Yakus v. United States
Yakus v. United States is a significant Supreme Court case decided in 1944 that addressed the constitutionality of price control regulations established during World War II. Following the U.S. entry into the war, Congress created the Office of Price Administration to implement measures aimed at curbing inflation through price controls. The case arose when Albert Yakus, a meat wholesaler, was convicted under the Emergency Price Control Act of 1942 and challenged the law's constitutionality. The Supreme Court, in a 6-3 decision led by Chief Justice Harlan Fiske Stone, upheld Yakus's conviction, asserting that the delegation of powers to the agency was permissible as Congress had set clear standards for its operation. The Court also ruled that the restrictions on judicial review were acceptable, as there remained adequate opportunities for courts to evaluate decisions. Dissenting Justice Wiley B. Rutledge argued that, while Congress could limit judicial involvement in administrative processes, any court involved should have the ability to assess the constitutionality of the laws being applied. The principles established in Yakus have had a lasting impact, influencing discussions on legislative delegation and judicial review in subsequent cases.
Yakus v. United States
Date: March 27, 1944
Citation: 321 U.S. 414
Issues: Delegation of congressional powers; separation of powers
Significance: In approving the Emergency Price Control Act of 1942, the Supreme Court upheld congressional power to limit judicial review in lower federal courts and to authorize an administrative agency to use wide latitude in fixing maximum prices and rents.
Soon after the United States entered World War II in 1941, Congress established the Office of Price Administration to set “fair and equitable” price controls for limiting inflation. Although violators of the regulations were tried in federal district courts, the statute specified that these courts could not rule on the constitutionality of the controls. Decisions of the courts were then reviewed by a special tribunal before going to the Supreme Court. Essentially the statute was designed to defer judicial review until late in the war effort. When Albert Yakus, a wholesaler of meats, was criminally punished under the Emergency Price Control Act of 1942, he challenged its constitutionality.
Speaking for a 6-3 majority, Chief Justice Harlan Fiske Stone upheld Yakus’s conviction. Although the Court in 1935 had imposed substantial limitations on the delegation of legislative powers, Stone found that the 1942 delegation was acceptable because Congress had provided standards to guide the agency’s work. Likewise, Stone wrote that the limitations on the courts were acceptable because there was sufficient opportunity for judicial review. In dissent, Justice Wiley B. Rutledge, Jr., wrote that although Congress might exclude the courts from the administrative process, if the courts were involved, they must be able to consider the constitutionality of their decisions. Rutledge’s dissent is widely respected. The Court appeared to affirm the delegation portion of Yakus in Mistretta v. United States (1989).