A.L.A. Schechter Poultry Corp. v. United States — 20-card Knowt set

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

Case about whether Congress gave too much lawmaking power to the President under the NIRA.

Who did what in Schechter

The Schechter brothers ran a Brooklyn slaughterhouse and were convicted of violating the Live Poultry Code.

What law was involved in Schechter

The National Industrial Recovery Act (NIRA), which let the President approve industry codes of fair competition.

What did the Live Poultry Code regulate

It set rules about wages, hours, inspections, and business practices in the poultry industry.

Main constitutional issue in Schechter

Whether the NIRA unconstitutionally delegated legislative power to the President.

Second issue in Schechter

Whether the federal government was regulating activity that was really intrastate, not interstate, commerce.

Holding on delegation

The Court said yes, Congress unconstitutionally delegated legislative power to the President.

Holding on commerce

The Court said Schechter’s slaughterhouse activity was intrastate commerce, not interstate commerce.

Legislative Vesting Clause

Article I says all legislative powers are vested in Congress.

Non-delegation doctrine

Congress cannot give away its essential lawmaking power to another branch.

What Congress can delegate

Congress can let agencies fill in details and find facts if Congress first gives clear policies and standards such as the intelligible principle.

What Congress failed to do in Schechter

Congress did not give real standards; it let the President approve almost any code he thought helpful.

Why “fair competition” was a problem

The term was too vague and broad, so it gave the President too much discretion.

What the Court thought the NIRA really allowed

It let the President or industry groups create whatever rules they thought were wise and beneficial.

Why the Court rejected the Great Depression Roosevelt argument?

The Court said a crisis does not increase constitutional power

"Extraordinary conditions do not create or enlarge constitutional power."

The Court; even a national emergency does not let the government go beyond the Constitution.

Key non-delegation quote

“Congress is not permitted to abdicate or to transfer to others the essential legislative functions…”

Why the ICC was different

The Interstate Commerce Commission had clearer legal standards and agencies only filled in details.

Why the NIRA was different

It gave the President and private industry broad power to make new rules without clear standards.

Cardozo’s famous line

“Delegation running riot”; the NIRA gave far too much lawmaking discretion away from Congress.

Best Schechter contrast

Congress may let agencies fill in details, but it cannot hand over basic lawmaking power itself.

Why the NIRA popular at first and why did the law become unpopular over time?

A New Deal law that was popular at first for helping businesses during the Great Depression, but became unpopular because it gave the President too much power without clear standards, leading to unfair outcomes and favoritsm.

Why did the Court say the codes violated non-delegation?

“Congress did not give clear standards and allowed the President to decide what was ‘fair,’ giving him too much legislative power.”

Describe the codes of fair competition and how they were negotiated

Industry rules on wages, hours, and prices made by business leaders, negotiated within industries (sometimes with labor), and then approved by the President Truman

How can Congress give the executive branch flexibility without violating non-delegation?

Congress must set clear policies and standards, while executive agencies can fill in the details and enforce the law.