Schechter Poultry Corp v. United States - Case Summary

Modified: 6th Mar 2025
Wordcount: 428 words

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Law Case Summary

Full Case Name: Schechter Poultry Corp. v. United States, 295 U.S. 495 (1935)

Facts

Schechter Poultry was charged with violations of the Live Poultry Code, established under Section 3 of the National Industrial Recovery Act. Section 3 allowed the President to adopt codes of conduct for businesses, to regulate and stabilise the US economy because of the Great Depression. The Schechter Poultry Corp. was convicted of violating the NRA's code by selling unfit chickens and for violating wage and hour provisions.

Issues

The main issue is whether or not the Congress delegated legislative powers to the President, under Section 3 of the National Industrial Recovery Act. This is a challenge to the division of powers in the Constitution.

Supreme Court Ruling

The Supreme Court unanimously ruled Section 3 of the National Industrial Recovery Act as unconstitutional. This is because it delegated legislative powers to the executive branch, which violates the Constitution's separation of powers. The Court also found the regulation of poultry was a state power, not a federal power, making it ultra vires.

Analysis

The case is a landmark judgement on the constitutional principle of non-delegation. The case established the powerful precedence of restricting Congress' ability to delegate its power. This decision thus reaffirms the constitutional principle of separation of powers, and the nature of federalism within the United States, by reaffirming state rights against federal intrusion (Netter, 2015).

References

  • Netter, J. M. (2015). 'The Growth of the Federal Government in the 1920s.' The Journal of Law & Economics, 33(2), 357-383.

Journalist Brief

This landmark case tested the limits of congressional power. In a unanimous decision, the Supreme Court struck down the National Industrial Recovery Act, ruling that it wrongly gave legislative powers to the President. The justices found regulations on intrastate businesses like Schechter Poultry were state matters. This pivotal case set key constitutional precedents limiting Congress’s ability to delegate powers, shaping federal legislation ever since.

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