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

Brief Fact Summary. A.L.A. Schechter Poultry Corporation (Petitioners) were convicted in the District Court of the United States for the Eastern District of New York for violating the Live Poultry Code, promulgated under Section:3 of the National Industrial Recovery Act.

Synopsis of Rule of Law. Congress is not permitted to abdicate or transfer to others the essential legislative functions with which it is vested by Article I of the Constitution of the United States.

Facts. Section:3 of the Act authorized the President to approve “codes of unfair competition” for trades and industries, and a violation of any code provision in any transaction in or affecting interstate or foreign commerce was made a misdemeanor punishable by a fine. The Live Poultry Code was approved by the President on April 13, 1934. Petitioners were convicted in the District Court for violating the Live Poultry Code, and contended that the Code had been adopted pursuant to an unconstitutional delegation by Congress of legislative power.

Issue. Did Congress, in authorizing the “codes of unfair competition” establish the standards of legal obligation, thereby performing its essential legislative function?

Held. No. The code-making authority conferred was an unconstitutional delegation of legislative power. Under Title 1, Section:1 of the Act there was a broad “Declaration of Policy,” and the President’s approval of a code was simply conditioned on his finding that it would “tend to effectuate the policy of this title.” The Act imposed no limitations on the scope of the new laws, and there was a very wide field of legislative possibilities. Dissent. None. Concurrence. The delegated power of legislation was unconfined and vagrant.

Discussion. Section:3 of the Act was without precedent in that it supplied no standards for any trade, industry or activity. Instead of prescribing rules of conduct, it authorized the President to make the codes to prescribe them. Congress made an unconstitutional delegation because it vested in the President a clearly legislative function without imposing necessary standards and restrictions.