Stark v. Wickard

Supreme Court of the United States
321 U.S. 288, 1944 U.S. LEXIS 1319, 64 S. Ct. 559 (1944)

ELI5:

Rule of Law:

When a federal statute creates a definite, personal legal right, such as the right to a minimum price for a commodity, an individual whose right is financially injured by an administrative action may seek judicial review of that action, even if the statute does not explicitly provide a remedy for that individual.

Facts:

Stark and other petitioners are producers of milk who deliver it to handlers in the 'Greater Boston' marketing area.
The Secretary of Agriculture, acting under the Agricultural Marketing Agreement Act of 1937, issued Order No. 4, which established a mechanism for setting a minimum price for milk.
The order created a producer settlement fund, into which handlers paid based on the use value of the milk they purchased.
From this fund, producers were paid a uniform 'blended price' for their milk.
The Secretary's order directed that certain sums be deducted from this fund before the blended price was calculated, including payments to cooperative associations.
The petitioners are not members of cooperative associations and therefore do not receive these payments.
This deduction for cooperatives directly reduced the final blended price paid to the petitioners for the milk they sold.

Procedural Posture:

Stark and other milk producers filed a class action suit in the U.S. District Court for the District of Columbia against the Secretary of Agriculture.
The suit sought an injunction to stop the Secretary from making certain deductions from the producer settlement fund.
The District Court dismissed the suit for failure to state a claim upon which relief could be granted, holding that the producers had no legal cause of action.
The producers, as appellants, appealed to the U.S. Court of Appeals for the District of Columbia.
The Court of Appeals affirmed the judgment of the District Court.
The producers successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the Court of Appeals' decision.

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Issue:

Does the Agricultural Marketing Agreement Act of 1937, by failing to explicitly provide a statutory remedy for milk producers, preclude them from bringing a suit in a federal district court to challenge the legality of a deduction from the producer settlement fund that directly reduces the price they receive for their milk?

Opinions:

Majority - Justice Reed

No. The Act does not preclude producers from seeking judicial review. When a federal statute creates a definite personal right, the silence of Congress as to judicial review is not to be construed as a denial of authority for an aggrieved person to seek appropriate relief in federal courts. The Agricultural Marketing Agreement Act and the Secretary's Order create a legal right for producers to receive a minimum price. The deduction for cooperatives directly and financially injures this right by reducing the price producers receive. Because every dollar of this deduction comes from the producer, they have a personal financial interest and thus have standing to challenge the statutory authority for the deduction. Unlike handlers, who were previously denied standing because they had no financial interest in the producer settlement fund, the producers' claim is based on a direct pecuniary loss stemming from the alleged misapplication of funds that are owed to them.

Dissenting - Justice Frankfurter

Yes. The Act does preclude producers from seeking judicial review. The availability of judicial review depends entirely on the specific statutory scheme Congress creates, and there is no common law of judicial review. The Agricultural Marketing Agreement Act is a self-contained code that provides a specific remedy for handlers but is deliberately silent on remedies for producers. This omission should be interpreted as a purposeful choice by Congress to withhold a judicial remedy from producers, who are given other means of influence such as hearings and the right to vote on orders. Creating a judicial remedy where Congress provided none dislocates the carefully balanced legislative scheme and improperly involves courts in the technical details of the milk industry. Furthermore, the producers lack standing because their only injury is a lower minimum price, but they can bargain for higher prices, and they have no direct legal interest in the settlement fund itself.

Analysis:

This decision solidifies the principle of a presumption of judicial review for administrative agency actions, even when the governing statute is silent on the matter. It establishes that for a party to have standing, they must demonstrate an infringement of a definite, personal right created by statute, often characterized by a direct financial injury. Stark v. Wickard is significant for administrative law because it limits the government's ability to claim that statutory silence precludes judicial oversight, thereby strengthening the role of the courts in ensuring agencies act within their congressionally delegated authority.

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