Schechter Poultry Corp. v. United States

Schechter Poultry Corp. v. United States (1935). The National Industrial Recovery Act (NIRA), passed in 1933, was President Franklin Delano Roosevelt's major effort to combat the Great Depression. Among other things, the act authorized industry groups, operating through the National Recovery Administration (NRA), to establish codes of fair competition. These codes, subject to presidential approval, affected such matters as wages, hours, working conditions, and methods of competition.

The Schechter brothers, owners of a small Brooklyn slaughterhouse, were convicted of violating the Live Poultry Code on several counts, including selling diseased chicken and filing false sales and price reports. They appealed, and in a unanimous 1935 ruling, the Supreme Court declared the NIRA unconstitutional. Speaking for the Court, Chief Justice Charles Evans Hughes said that the law failed to provide adequate guidance concerning what matters the codes would cover. As a result, the NIRA unconstitutionally delegated legislative power to the executive branch. Hughes further argued that the poultry code violated the commerce clause of the Constitution (art. I, sec. 8). According to past cases, Congress could only regulate intrastate activity having a “direct” impact on interstate commerce. The Schechters' local commercial activity, Hughes noted, was clearly “indirect.” While Roosevelt accused the Supreme Court of possessing an anachronistic view of the Constitution, he was not sorry to see the unwieldy and unworkable NRA dismantled. Indeed, the Schechter decision prompted more careful drafting of New Deal legislation in the future. While this decision has not been explicitly overruled, later justices abandoned the nondelegation doctrine and the distinction between direct and indirect effects enunciated therein. Some scholars regarded this development as a necessary jurisprudential response to an increasingly complicated world. Others argued, however, that the Court has merely encouraged Congress to renounce its legislative duties.
See also Economic Regulation; New Deal Era, The.

Bibliography

Robert G. McCloskey , The American Supreme Court, 2d ed., 1994.

Jeffrey D. Hockett