A.L.A. Schechter Poultry Corp. v. United States (1935)

Quick Summary

In Schechter Poultry (1935), the U.S. Supreme Court struck down the Live Poultry Code, made under the National Industrial Recovery Act (NIRA). The Court said Congress had given the President a free hand to make rules without clear limits. That move violated the nondelegation doctrine—Congress cannot hand over its core law-making job without clear standards.

Issues

• Was the Live Poultry Code and the convictions under it valid?
• Did Congress, by authorizing broad “codes of unfair competition,” set the standards of legal duty—or did it hand its legislative power to the President?

Rules

• Necessary and Proper Clause: Congress may pass laws needed to carry out its powers (U.S. Const. art. I, §8, cl. 18).
• Nondelegation Principle: Congress cannot abdicate or transfer its essential law-making function to others without clear, guiding standards.

Facts (Timeline)

Arguments

Judgment

The Supreme Court invalidated the code-making scheme. The Act’s broad policy statement did not supply workable standards. The President’s power to approve codes functioned as open-ended law-making. The convictions could not stand.

Commerce holding (brief): The activities were local and had come to rest after interstate movement; the commerce power did not extend to them.

Ratio

Congress cannot transfer its core legislative function to the Executive without clear, narrow, and intelligible standards. Section 3 of the NIRA left law-making “unconfined and vagrant,” which violates the nondelegation doctrine.

Why It Matters

This case is a landmark on limits to executive rule-making. It teaches that broad goals are not enough; Congress must draw clear lines. It remains a key citation in debates on agency power and separation of powers.

Key Takeaways

• Nondelegation = No blank checks. Congress must supply real standards.
• Policy statements alone do not control executive discretion.
• Local activity after goods “come to rest” may fall outside interstate commerce.

Mnemonic + 3-Step Hook

Mnemonic: “NO CODE, NO CONGRESS” — No code-making without Congress drawing the code lines.

1. Name the rule: Congress needs clear standards.
2. Spot the problem: NIRA gave open-ended approval power.
3. State the result: Code struck; convictions reversed.

IRAC Outline

Issue: Did Congress unlawfully delegate legislative power through the Live Poultry Code?

Rule: Congress may not transfer essential law-making duties without clear standards to guide the delegate.

Application: The Act had a broad policy and left the President to fill in binding rules. That discretion was too wide; it created crimes by executive approval.

Conclusion: The delegation was unconstitutional; the Code and convictions fell.

Glossary

Nondelegation Doctrine

Limit that stops Congress from giving away core law-making power.

Intelligible Principle

Clear guidance Congress must set for any delegation.

Come to Rest

Goods no longer moving in interstate commerce; activity becomes local.

FAQs

Related Cases

• Panama Refining Co. v. Ryan — Another 1935 case limiting NIRA delegations.
• J.W. Hampton, Jr. & Co. v. US — Introduced the “intelligible principle” idea.
• Gundy v. United States — Modern debate on nondelegation revival.