A.L.A. Schechter Poultry Corp. v United States
295 U.S. 495 (1935)
- As part of the New Deal, the National Industrial Recovery Act (NIRA), authorized the President to approve “codes of fair competition,” developed by boards from various industries. The Live Poultry Code established minimum wages, child labor laws, and union rights in the poultry industry.
- Schechter owned a poultry slaughterhouse in NY. The poultry they processed came from out of state farms, but was sold to NY retailers. They were violating minimum wage and “sick chicken” parts of the Live Poultry Code.
- The US Supreme Court unanimously struck down the Live Poultry Code.
- The Court felt that the fact there was a depression did not give Congress enlarged powers.
- The Court felt that even though the poultry came from out of State. The interstate part of the commerce ended when the birds entered Schechter’s slaughterhouse. The people employed by Schechter were not involved in interstate commerce.
- The 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 Interstate Commerce Clause.
- Basically, Congress cannot give away its power. This is known as the Nondelegation Doctrine.
- Congress can authorize Executive Agencies to make laws, but Congress is supposed to be very specific about telling the Agency what to do and what not to do. Or course, in the present day, Executive Agencies operate with only minimal guidance from Congress.
- This narrow reading of the Commerce Clause was later disavowed by the Court, which began to read congressional power more expansively in this area.