Schechter Poultry Corp. v. United States
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| Schechter Poultry Corp. v. United States | ||||||||
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 Supreme Court of the United States | ||||||||
| 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 affirmed in part, reversed in part. | ||||||||
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| Laws applied | ||||||||
| U.S. Const. art. I, X; 15 U.S.C.S. § 703 (1933) (National Industrial Recovery Act § 3) |
Disparagingly known as "the sick chicken case," A.L.A. Schechter Poultry Corp. v. United States, 295 U.S. 495 (1935), 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. 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).
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 imperssible 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 matters of purely 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 affect 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 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.
External links
- Full text of the decision courtesy of Findlaw.com (http://laws.findlaw.com/us/295/495.html)