Schechter Poultry Corp. v. United States
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| Schechter Poultry Corp. v. United States | ||||||||||||
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| Argued May 2–3, 1935 Decided May 27, 1935 |
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| Holding | ||||||||||||
| Section 3 of the National Industrial Recovery Act was an unconstitutional delegation of legislative power to the Executive, and was not a valid exercise of congressional Commerce Clause power. Second Circuit Court of Appeals affirmed in part, reversed in part. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Charles Evans Hughes Associate Justices: Willis Van Devanter, James Clark McReynolds, Louis Brandeis, George Sutherland, Pierce Butler, Harlan Fiske Stone, Owen Josephus Roberts, Benjamin N. Cardozo |
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| Case opinions | ||||||||||||
| Majority by: Hughes Joined by: Van Devanter, McReynolds, Brandeis, Sutherland, Butler, Roberts Concurrence by: Cardozo Joined by: Stone |
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| Laws applied | ||||||||||||
| U.S. Const. art. I; U.S. Const. amend. X; 15 U.S.C. § 703 (1933) (National Industrial Recovery Act § 3) | ||||||||||||
A.L.A. Schechter Poultry Corp. v. United States, 295 U.S. 495 (1935), was a decision by the Supreme Court of the United States that invalidated regulations of the poultry industry promulgated under the authority of the National Industrial Recovery Act of 1933. These included price and wage fixing, as well as requirements regarding a whole shipment of chickens, including unhealthy ones, which has led to the case becoming known as "the sick chicken case." Also encompassed in the decision were NIRA provisions regarding maximum work hours and a right of unions to organize. The ruling was one of a series which overturned elements of President Franklin D. Roosevelt's New Deal legislation between January 1935 and January 1936, until the Court's intolerance of economic regulations shifted with West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937). The National Industrial Recovery Act allowed local codes for fair trade to be written by private trade and industrial groups. The President could choose to give some codes the force of law. The Supreme Court's opposition to an active government role caused Roosevelt to attempt to pack the Court with judges that were in favor of the New Deal.
There were originally sixty charges against Schechter Poultry, which were reduced to eighteen charges plus charges of conspiracy by the time the case was heard by the U. S. Supreme Court.
Among the eighteen charges against Schechter Poultry were "the sale to a butcher of an unfit chicken" and the sale of two uninspected chickens.
[edit] The Court's Decision
Chief Justice Hughes wrote for a unanimous Court in invalidating the industrial "codes of fair competition" which the NIRA enabled the President to issue. The Court held that the codes violated the constitutional separation of powers as an impermissible delegation of legislative power to the executive branch. The Court also held that the NIRA provisions were in excess of congressional power under the Commerce Clause.
The Court distinguished between direct effects on interstate commerce, which Congress could lawfully regulate, and indirect, which were purely matters of state law. Though the raising and sale of poultry was an interstate industry, the Court found that the "stream of interstate commerce" had stopped in this case—Schechter's slaughterhouses bought chickens only from intrastate wholesalers and sold to intrastate buyers. Any interstate effect of Schechter was indirect, and therefore beyond federal reach.
Though many considered the NIRA a "dead statute" at this point in the New Deal scheme, the Court used its invalidation as an opportunity to impose limits on congressional power, for fear that it could otherwise reach virtually anything that could be said to "affect" interstate commerce and intrude on many areas of legitimate state power.
Justice Cardozo's concurring opinion clarified that a spectrum approach to direct and indirect effects is preferable to a strict dichotomy. Cardozo felt that in this case, Schechter was simply too small a player to be relevant to interstate commerce.
This narrow reading of the Commerce Clause was later disavowed by the Court, which, after West Coast Hotel v. Parrish (1937) began to read congressional power more expansively in this area. However, more recent cases such as United States v. Lopez, 514 U.S. 549 (1995) perhaps signal a growing inclination in the Court to once again impose limits on its scope.
