Amalgamated Meat Cutters & Butcher Workmen of North America, AFL-CIO v. Connally

United States District Court for the District of Columbia, three-judge district court · Administrative Law

Administrative Lawnondelegationjudicial reviewadministrative procedureeconomic stabilizationEconomic Stabilization Act of 1970Executive Order 11615intelligible principle

Facts

The union alleged that its 1970 collective bargaining agreements with major meatpacking companies required a general wage increase effective September 6, 1971, and that the increase was a crucial part of the bargain. The employers responded that paying the increase would violate Executive Order 11615, which imposed a 90-day freeze stabilizing prices, rents, wages, and salaries. The union then challenged both the Economic Stabilization Act of 1970 and the Executive Order as unconstitutional and invalid on their face and sought to stop federal officials from administering them. The Act authorized the President to issue orders and regulations to stabilize prices, rents, wages, and salaries, allowed adjustments to prevent gross inequities, restricted industry-specific controls absent particular findings, permitted delegation, and expired on April 30, 1972.

Issue

Whether the Economic Stabilization Act of 1970 unconstitutionally delegated legislative power to the President by authorizing him to issue orders and regulations to stabilize prices, rents, wages, and salaries, including the timing and scope of a general 90-day freeze under Executive Order 11615. Also, whether the Act and order were invalid because of alleged lack of standards, inadequate provision for fairness, judicial review, and application to existing contracts and fringe benefits.

Rule

A delegation of legislative authority is constitutionally permissible if Congress has exercised the essentials of the legislative function by establishing policy and an intelligible principle, and if the statute, viewed in light of its text, purpose, legislative history, and historical context, sufficiently marks the field so that it can be determined whether the Executive has complied with the legislative will. In this setting, the Act also carries an implicit duty of broad fairness and avoidance of gross inequity in follow-on controls after the initial freeze, requires development of subsidiary administrative standards, and remains subject to the Administrative Procedure Act's procedural and judicial review provisions absent clear contrary legislative intent.

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Congress enacts the National Housing Cost Stabilization Act, authorizing the President for eight months to issue orders "as he deems appropriate" to stabilize residential rents and construction labor rates nationwide, but not below levels prevailing on a stated prior date. The statute also permits adjustments necessary to prevent gross inequities and was enacted against a well-known history of prior federal stabilization programs in the same field. A landlords' association in Phoenix argues the statute is unconstitutional because it contains no detailed formula for when or how controls must be imposed.

How should a court most likely rule on the facial nondelegation challenge?

Explanation. The majority upheld a broad stabilization delegation where the statute, viewed in light of text, purpose, legislative history, and historical context, sufficiently marked the field for courts, Congress, and the public to determine compliance with legislative will. The presence of a floor, a gross-inequity adjustment provision, limited duration, and a background of prior stabilization practice defeats the claim that the President received an unconstitutional blank check. The opinion also rejected the notion that validity depended crucially on wartime conditions. (Derived from Amalgamated Meat Cutters & Butcher Workmen of North America, AFL-CIO v. Connally (n.d.).)