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Humphrey's Executor v. United States


HUMPHREY'S EXECUTOR V. UNITED STATES, 295 U.S. 602 (1935), restricted the president's power to remove members of the so-called independent agencies. In October 1933, President Franklin D. Roosevelt removed Federal Trade Commissioner William E. Humphrey, not for neglect of duty or malfeasance, as stipulated in the Federal Trade Commission Act, but because of differences of opinion. Humphrey denied the validity of this action, and, in a suit that continued after Humphrey's death, the Supreme Court held unanimously that Congress intended to create the Federal Trade Commission as an independent body and therefore meant to limit the president's removal power to the causes enumerated in the act, and that such limitations were not unconstitutional. Congress has authority, the Court declared, to require such a body to act independently of executive control and may forbid removal except for cause.


Herring, E. Pendleton. Public Administration and the Public Interest. New York: Russell and Russell, 1967. The original edition was published in 1936.

Leuchtenburg, William E. "The Case of the Contentious Commissioner: Humphrey's Executor v. U.S." In Freedom and Reform: Essays in Honor of Henry Steele Commager. Edited by Harold M. Hyman and Leonard W. Levy. New York: Harper and Row, 1967.

Ransom E.NobleJr.

Andrew C.Rieser/a. r.

See alsoFederal Agencies ; Myers v. United States ; Removal, Executive Power of .

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