Law School Case Brief
Amalgamated Meat Cutters & Butcher Workmen v. Connally - 337 F. Supp. 737 (D.D.C. 1971)
Congress is free to delegate legislative authority provided it has exercised the essentials of the legislative function of determining the basic legislative policy and formulating a rule of conduct.
Plaintiff union sought injunctive relief from defendants' enforcement of the Economic Stabilization Act of 1970, 12 U.S.C.S. § 1904, and Exec. Order No. 11615, 36 Fed. Reg. 15727. Plaintiff also challenged the constitutionality of that Act and that Executive Order. Plaintiff argued that 12 U.S.C.S. § 1904 unconstitutionally delegated legislative power to the President, in violation of the general constitutional principle of the Separation of Powers, and in contravention of the U.S. Const. art. I, § 1.
Did the Economic Stabilization Act of 1970 and Executive Order unconstitutionally delegate legislative power to the President, thereby warranting the grant of injunctive relief to plaintiffs?
The Court noted that Congress was free to delegate legislative authority provided it had exercised the essentials of the legislative function of determining the basic legislative policy and formulating a rule of conduct. In the case at bar, the court held that there was not such an absence of standards in 12 U.S.C.S. § 1904 that would have made it impossible to ascertain whether the will of Congress had been obeyed. According to the court, Congress limited the President's authority to stabilize prices and wages at levels not less than those prevailing on May 25, 1970. The President was required to impose controls on the entire economy, not just a single sector. As such, the plaintiff’s motion for a preliminary injunction was denied.
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