United States v. Curtiss-Wright

Citation. 229 U.S. 304 (1936)

Brief Fact Summary.

Congress issued a Joint Resolution authorizing the president to prohibit the sale of arms to countries engaged in an armed conflict in Chaco.

Synopsis of Rule of Law.

To maintain international relations, Congress can accord the President a degree of discretion and freedom from statutory restriction that would not be available when only domestic affairs are at issue.

Facts.

In 1934, Congress passed a Joint Resolution authorizing the President to prohibit the sale of arms to countries engaged in an armed conflict in the Chaco. The same day, the President issued a proclamation prohibiting such arms sales. Appellees were charged with violating Congress’ Joint Resolution and the President’s proclamation.

Issue.

Was Congress’ delegation of authority to the executive in its Joint Resolution invalid?

Held.

No, Congress’ delegation of authority to the executive was not invalid.

Discussion.

The federal government’s sovereignty, including the power to declare war and maintain diplomatic relations, does not depend on the Constitution. Additionally, the President is the nation’s sole representative in external affairs. To maintain international relations, Congress can accord the President a degree of discretion and freedom from statutory restriction that would not be available when only domestic affairs are at issue.