Amalgamated Meat Cutters & Butcher Work. v. Connally
337 F.Supp. 737 (1971)
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Rule of Law:
A broad delegation of legislative power from Congress to the President is constitutional so long as Congress lays down an intelligible principle to which the President must conform. The presence of such a principle can be determined from the statute's text, its legislative history, its historical context, and the availability of judicial review to ensure executive actions comply with the legislative will.
Facts:
- In April 1970, the Amalgamated Meat Cutters union entered into collective bargaining agreements with several major meat packing companies.
- These agreements included a provision for a general wage increase of twenty-five cents per hour, scheduled to take effect on September 6, 1971.
- Congress passed the Economic Stabilization Act of 1970, which authorized the President 'to issue such orders and regulations as he may deem appropriate to stabilize prices, rents, wages, and salaries'.
- On August 15, 1971, President Richard Nixon issued Executive Order 11615, instituting a 90-day nationwide freeze on all wages, salaries, prices, and rents.
- Citing the Executive Order, the meat packing companies refused to pay the contractually-obligated wage increase that was due to take effect on September 6, 1971.
- The union had numerous other contracts with employers in various industries that also provided for wage increases scheduled to take effect during the 90-day freeze, affecting over 150,000 employees.
Procedural Posture:
- The Amalgamated Meat Cutters union filed a two-count complaint in a U.S. District Court.
- Count I, against Secretary of the Treasury John B. Connally and other members of the Cost of Living Council, sought a declaratory judgment that the Economic Stabilization Act of 1970 was unconstitutional and an injunction to block its enforcement.
- Count II sought to compel the major meat packing companies to perform their contractual obligation to grant a wage increase.
- Pursuant to federal law, a three-judge District Court was convened because the suit sought to enjoin the enforcement of a federal statute on constitutional grounds.
- The Union then filed a motion for a preliminary injunction.
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Issue:
Does the Economic Stabilization Act of 1970, which grants the President broad authority to 'stabilize prices, rents, wages and salaries' without providing detailed and specific standards, constitute an unconstitutional delegation of legislative power to the Executive?
Opinions:
Majority - Leventhal, Circuit Judge
No, the Economic Stabilization Act of 1970 does not constitute an unconstitutional delegation of legislative power because Congress provided an intelligible principle for the President to follow. The constitutional requirement of accountability is met when it is possible for courts and the public to ascertain whether the executive has acted in compliance with the legislative will. While the Act confers broad authority, it is not a 'blank check.' The court found sufficient standards by looking beyond the text of the Act itself to its legislative history, historical context, and implicit requirements. The legislative history, particularly the House Committee Report, articulated a clear purpose: to combat cost-push inflation, protect consumers and wage earners, and provide the President with tools for economic stability. The Act was passed against a background of prior price-control statutes from World War II and the Korean War, which provide a 'common lore' and framework that informs the scope of the delegated authority. The court also inferred a standard of 'broad fairness and avoidance of gross inequity' from the Act's text, which prevents the President from acting arbitrarily. Finally, the availability of judicial review under the Administrative Procedure Act provides a crucial check on executive power, ensuring that the President's actions can be challenged in court to determine if they conform to the legislative mandate. The court distinguished this case from precedents like Schechter Poultry, characterizing them as extremist examples of 'delegation run riot' that are not analogous to the limited-duration and contextually-grounded authority granted here.
Analysis:
This decision reaffirms the modern, flexible approach to the nondelegation doctrine, solidifying the precedent set in Yakus v. United States and cementing the decline of the stricter standard from Schechter Poultry. The court demonstrates its willingness to find an 'intelligible principle' by looking beyond the statutory text to legislative history, historical context, and the availability of judicial review. This pragmatic approach grants Congress significant latitude to delegate broad discretionary authority to the executive branch, particularly to address complex and dynamic national problems like economic instability. The ruling effectively lowers the bar for what constitutes a sufficient standard, making successful nondelegation challenges to federal statutes exceptionally difficult.
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