United States v. Butler

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Schechter Poultry Corp. v. United States Citation: 295 U.S. 495 (1935) Concepts: Congressional Power v. Presidential Power/Commeme Clause/"Sick Chickens" Facts During the Great Depression, President Franklin Delano Roosevelt established an economic recovery program known as the "New Deal." As part of the program, the President established the National Industrial Recovery Act of 1933 (NIRA) which authorized the President to set "codes of fair competition," regulating certain facets of interstate commerce. The Schechter Poultry Corp. bought, slaughtered, and sold chickens only in New York State, although some of the chickens were purchased from other states. Schechter was indicted for disobeying the "live poultry code," one of the codes of fair competition. The government alleged that Schechter failed to observe minimum wage and hour provisions, permitted customers to select individual chickens from particular coops and half-c~ops, sold unfit and uninspected chickens, and made false reports. Schechter appealed his conviction. Issue Whether the National Industrial Recovery ACt, which gave the President the authority to regulate certain aspects of commerce during the Depression, was an unconstitutional delegation of presidential power. Opinion The Supreme Court of the United States, in a unanimous decision, held that the delegation of power made by the NIRA was unconstitutional. The Court held that Congress has the power to regulate interstate commeme, not the President, and that Congress cannot delegate legislative power to the President. Even the extraordinary conditions of the Depression were not enough for the Court to allow the President to have more power than the Constitution gave him. Schechter s conviction was reversed because its business indirectly affected interstate commeme. The NIP, A was declared unconstitutional because it exceeded the commerce power that had been given to Congress.by the Constitution. United States v. Butler Citation: 297 U.S. 1 (1936) Concepts: Federalism/Taxation/ State Rights Facts As part of the 1933 Agricultural Adjustment Act, the United States Congress implemented a tax on the processing of agricultural commodities, from which funds would be redistributed to farmers who promised to reduce their production of the same agricultural commodities. The Act intended to solve the crisis in agricultural commodity pricing during America s Great Depression. 2O

ssue Whether the United States Congress exceeded its power to tax and spend in order to provide for the general welfare, granted by Article I, Section 8, Clause 1, of the Constitution of the United States, and violated the states Tenth Amendment right to taxation, by enacting the Agricultural Adjustment Act. Opinion In a 6-3 decision, the Supreme Court of the United States found the Act unconstitutional because it attempted to regulate and control agricultural production, an area reserved to the states. Even though the United States Congress has the power to tax and appropriate funds, in this case those activities were "but means to an unconstitutional end," and were therefore in violation of the reserved powers the states have under the Tenth Amendment. National Labor Relations Board v. Jones & Laughlin Steel Corp. Citation: 301 U.S. 57 (1937) Concepts: Commerce/Labor Relations/ Unionism Facts In a proceeding under the National Labor Relations Act of 1935, the National Labor Relations Board (NLRB) found that the Jones & Laughlin Steel Corporation had violated the act by firing ten union members because of their union membership. The NLRB demanded the steel company stop discrimination against union workers; the corporation failed to comply. The Circuit Court of Appeals refused to enforce the order of the NLRB holding that the order was outside the range of federal power. Issue Whether or not the United States Congress involvement in labor relations went beyond its means to regulate interstate commerce, as found in Article I, Section 8, Clause 3 of the Constitution of the United States. Opinion The Supreme Court of the United States ruled 5-4 in favor of the NLRB, stating that Congress has ability to regulate intrastate matters when they directly burden, threaten, or obstruct interstate commeme. A labor stdke in the steel factory would disrupt the "stream of commerce," and would have a direct effect on the flow of interstate commerce. Therefore, Congress has the power to regulate all trade which may upset the balance between interand intrastate commerce. 21

FDR & the Supreme court His complaints His plan Criticism of his plan :Factors contributing to its failure Conclusions

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