Cases - 1934 term

Schechter Poultry Corp. v. United States

Thu, 02 May 1935 13:00:00 +0000

Location

Schechter Poultry Slaughterhouse Markets

858 E. 52 Street Brooklyn NY 11203

Brooklyn, NY 11203

United States

40° 38' 21.3" N, 73° 55' 37.5924" W

See map: Google Maps

Case Basics

Docket No.

854

Petitioner

Schechter Poultry Corp.

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

295 U.S. 495 (1935)

Argued

Thursday, May 2, 1935

Decided

Monday, May 27, 1935

Facts of the Case

Section 3 of the National Industrial Recovery Act empowered the President to implement industrial codes to regulate weekly employment hours, wages, and minimum ages of employees. The codes had standing as penal statutes.

Question

Did Congress unconstitutionally delegate legislative power to the President?

Conclusion

Decision: 9 votes for Schechter Poultry Corp., 0 vote(s) against
Legal provision: U.S. Const. Art I; U.S. Const. Amend. 10; 15 U.S.C. § 703 (1933) (National Industrial Recovery Act § 3)

The Court held that Section 3 was "without precedent" and violated the Constitution. The law did not establish rules or standards to evaluate industrial activity. In other words, it did not make codes, but simply empowered the President to do so. A unanimous Court found this to be an unconstitutional delegation of legislative authority.

Humphrey's Executor v. United States

Wed, 01 May 1935 13:00:00 +0000

Location

The White House

1600 Pennsylvania Ave Washington DC 20500

Washington, DC 20500

United States

38° 53' 51.7056" N, 77° 2' 11.4684" W

See map: Google Maps

Case Basics

Docket No.

667

Petitioner

Humphrey's Executor

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

295 U.S. 602 (1935)

Argued

Wednesday, May 1, 1935

Decided

Monday, May 27, 1935

Facts of the Case

President Hoover appointed, and the Senate confirmed, Humphrey as a commissioner of the Federal Trade Commission (FTC). In 1933, President Roosevelt asked for Humphrey's resignation since the latter was a conservative and had jurisdiction over many of Roosevelt's New Deal policies. When Humphrey refused to resign, Roosevelt fired him because of his policy positions. However, the FTC Act only allowed a president to remove a commissioner for "inefficiency, neglect of duty, or malfeasance in office." Since Humphrey died shortly after being dismissed, his executor sued to recover Humphrey's lost salary.

Question

Did section 1 of the Federal Trade Commission Act unconstitutionally interfere with the executive power of the President?

Conclusion

Decision: 9 votes for Humphrey's Executor, 0 vote(s) against
Legal provision: US Const Art 1 and 2; Federal Trade Commission Act

The unanimous Court found that the FTC Act was constitutional and that Humphrey's dismissal on policy grounds was unjustified. The Court reasoned that the Constitution had never given "illimitable power of removal" to the president. Justice Sutherland dismissed the government's main line of defense in this case which relied heavily on the Court's decision in Meyers v. United States (1926). In that case the Court upheld the president's right to remove officers who were "units of the executive department." The FTC was different, argued Sutherland, because it was a body created by Congress to perform quasi- legislative and judicial functions. The Meyers precedent, therefore, did not apply in this situation.

Perry v. United States

Thu, 10 Jan 1935 13:00:00 +0000

Case Basics

Docket No.

532

Petitioner

Perry

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

294 U.S. 330 (1935)

Argued

January 10-11, 1935

Decided

Monday, February 18, 1935

Facts of the Case

None

Question

None

Conclusion

None

Panama Refining Co. v. Ryan

Mon, 10 Dec 1934 13:00:00 +0000

Case Basics

Docket No.

135

Petitioner

Panama Refining Co.

Petitioner Type

Petitioner

Respondent

Ryan

Respondent Type

Respondent

Consolidation

Amazon Petroleum Corp. v. Ryan, No. 260

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

293 U.S. 388 (1935)

Argued

December 10-11, 1934

Decided

Monday, January 7, 1935

Facts of the Case

None

Question

None

Conclusion

None

Baldwin v. G. A. F. Seelig, Inc.

Mon, 11 Feb 1935 13:00:00 +0000

Case Basics

Docket No.

604

Appellee

G. A. F. Seelig, Inc.

Petitioner Type

Appellee

Appellant

Baldwin, Commissioner of Agriculture and Markets, et al.

Respondent Type

Appellant

Consolidation

G. A. F. Seelig, Inc. v. Baldwin, Commissioner of Agriculture and Markets, et al., No. 605

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

294 U.S. 511 (1935)

Argued

February 11-12, 1935

Decided

Monday, March 4, 1935

Facts of the Case

None

Question

None

Conclusion

None

Grovey v. Townsend

jgoldman — Mon, 11 Mar 1935 13:00:00 +0000

Location

Harris County Clerk

201 Caroline Street Houston TX 77002

Houston, TX 77002

United States

29° 45' 38.934" N, 95° 21' 27.4572" W

See map: Google Maps

Case Basics

Docket No.

563

Petitioner

R. R. Grovey

Petitioner Type

Petitioner

Respondent

Townsend

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

295 U.S. 45 (1935)

Argued

Monday, March 11, 1935

Decided

Monday, April 1, 1935

Advocates

J. Alston Atkins (argued the cause for the petitioner)

Facts of the Case

R. R. Grovey, an African-American, attempted to vote in the Democratic primary election held on July 28, 1934 and was denied a ballot by the county clerk specifically because of his race. The whites-only restriction of the Texas Democratic Party had been passed by a convention in May 1932. Grovey sued, arguing the restriction violated his rights under the Fifteenth Amendment and the Equal Protection Clause of the Fourteenth Amendment. A Justice Court in Texas denied his claim.

Question

Did the Democratic Party's refusal to allow Grovey a ballot in the primary election violate his rights under the Fourteenth and Fifteenth Amendments?

Conclusion

No. In a unanimous opinion authored by Justice Owen Roberts, the Court concluded that the party's restriction had not been authorized or endorsed by the state and therefore was free from the limitations of the Fourteenth and Fifteenth Amendments. The Court had previously ruled in Nixon v. Herndon (1927) and Nixon v. Condon (1932) that the state could not impose such race- based limitations in primaries. However, Justice Roberts noted that the party's rule in Grovey's case could not be limited by the amendments. Justice Roberts wrote that "the Democratic party in that state is a voluntary political association and, by its representatives assembled in convention, has the power to determine who shall be eligible for membership and, as such, eligible to participate in the party's primaries."