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Yakus v. United States

Supreme Court of the United States · 1944 · Constitutional Law

Constitutional LawNondelegationDue ProcessJudicial ReviewWar PowersCriminal ProcedureEmergency Price Control Actexclusive jurisdiction

Facts

The Emergency Price Control Act authorized the Price Administrator to issue maximum price regulations under stated statutory standards and created a special review process: protest to the Administrator, review in the Emergency Court of Appeals, and certiorari in the Supreme Court. Petitioners sold wholesale cuts of beef above the maximum prices fixed by Revised Maximum Price Regulation No. 169 and were indicted and convicted for willful violations. They did not use the statutory protest and review procedure to challenge the regulation, and by the time of indictment the original sixty-day protest period had expired. At trial they sought to defend by arguing that the regulation failed to conform to the Act and deprived them of property without due process, but the district court excluded that evidence as irrelevant.

Issue

Whether the Emergency Price Control Act unconstitutionally delegated legislative power to the Price Administrator; whether § 204(d) made the statutory protest-and-review procedure the exclusive means of testing a price regulation's validity, thereby barring validity as a defense in a criminal prosecution; and whether that exclusivity, together with the stay provisions, violated due process, the Sixth Amendment, or the judicial power.

Rule

Congress may delegate price-fixing authority if it declares the legislative policy, prescribes the method of carrying it out, and provides standards sufficiently definite to confine administrative discretion and permit judicial review for compliance with the legislative will. Congress may also vest exclusive jurisdiction over the validity of administrative regulations in a specialized court and bar other courts from considering validity in enforcement proceedings, including criminal prosecutions, provided the statutory review procedure gives affected parties a reasonable opportunity to be heard and obtain judicial review consistent with due process.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress enacts a temporary emergency statute authorizing the Market Stabilization Director to cap wholesale lumber prices during a declared national crisis. The statute states that the objective is to prevent inflation and supply disruption, requires prices to be generally fair and equitable, directs the Director to use a designated base period so far as practicable, and permits adjustments for listed factors such as transportation costs and abnormal market swings. A wholesaler in Portland, Oregon is prosecuted for knowingly charging above the ceiling and argues the statute is an unconstitutional delegation because Congress did not itself set the prices numerically.

How should a court rule on the delegation challenge?

Explanation. The majority held that a delegation is valid when Congress declares the legislative objective, prescribes the method of achieving it, and lays down standards sufficient to mark the field of administrative action so courts can determine whether Congress's will has been obeyed. A scheme using emergency price ceilings, a stated anti-inflation objective, fairness standards, a base period, and specified adjustments satisfies that test even though Congress could have chosen a more rigid system.