The following case brief for A.L.A. Schechter Poultry Corp. v. United States (1935) provides a concise and structured summary of the court case that serves as a valuable reference tool for law students and legal professionals. It allows them to review and analyze legal principles, identify key issues and holdings, and gain insight into the court’s reasoning.
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Case: A.L.A. Schechter Poultry Corp. v. United States
| Court: | Supreme Court of the United States |
| Citation: | 295 U.S. 495 (1935) |
| Petitioner: | A.L.A. Schechter Poultry Corp., et al. |
| Respondent: | United States |
Procedural History: Schechter v. United States (1935)
- The case originated in the United States District Court for the Eastern District of New York, where A.L.A. Schechter Poultry Corp. and other related entities were charged with violating provisions of the National Industrial Recovery Act (NIRA).
- The defendants were found guilty, and the case was appealed to the United States Supreme Court.
Facts: A.L.A. Schechter Poultry Corp. v. United States
A.L.A. Schechter Poultry Corporation (Schechter) was a family-owned business engaged in the poultry industry in Brooklyn, New York. The National Industrial Recovery Act (NIRA) was enacted in response to the Great Depression and aimed to revive industrial and economic activities.
Under the NIRA, the President was granted the authority to approve “codes of fair competition” for various industries, which would regulate working conditions, wages, and other aspects of commerce. The Live Poultry Code was one such code approved by the President, and Schechter was charged with violating this code.
Issue: Schechter v. United States (1935)
The main issue before the court was whether the Live Poultry Code, promulgated under the authority of the NIRA, exceeded the scope of Congress’s constitutional power to regulate interstate commerce and violated the nondelegation doctrine.
Rule of Law: A.L.A. Schechter Poultry Corp. v. United States
The Court considered the constitutionality of the Live Poultry Code under the Commerce Clause and the nondelegation doctrine.
Holding and Reasoning: Schechter v. United States (1935)
The Supreme Court held that the Live Poultry Code, as implemented under the NIRA, was unconstitutional.
Holding: The Court, by a unanimous decision, declared the Live Poultry Code unconstitutional.
Reasoning: The Court’s reasoning involved two main aspects:
- Nondelegation Doctrine: The Court first addressed the issue of whether Congress had unconstitutionally delegated its legislative powers to the President. The Court held that the NIRA, as written, granted the President broad discretion to approve codes of fair competition without providing clear guidelines or standards for such approval. This delegation of authority was deemed unconstitutional since it violated the nondelegation doctrine, which requires Congress to establish an intelligible principle to guide the exercise of delegated powers.
- Scope of Congressional Power: The Court then examined whether the Live Poultry Code, as a regulation of intrastate poultry transactions, exceeded Congress’s authority to regulate interstate commerce. The Court concluded that the activities regulated by the code were primarily local in nature and did not have a substantial effect on interstate commerce. Therefore, Congress had exceeded its constitutional authority by attempting to regulate intrastate activities under the guise of regulating interstate commerce.
Concurrence and Dissent: Schechter v. United States
There were no formal written concurrences or dissents in this case.
Significance: Schechter v. United States (1935)
The Schechter Poultry case is important because it marked a significant limitation on Congress’s power to delegate legislative authority and clarified the scope of the Commerce Clause. The Court’s ruling established that there are limits to the delegation of legislative power and that Congress cannot regulate purely intrastate activities under the guise of regulating interstate commerce.
This case played a role in shaping the Court’s interpretation of the Commerce Clause in subsequent cases and highlighted the importance of maintaining the separation of powers between the legislative and executive branches.