Blaisdell concerned the temporary suspension of creditor's remedies by Minnesota in order to combat mortgage foreclosures, finding that temporal relief did not in fact impair the obligation of a contract.
[8] Chief Justice Charles Evans Hughes arranged for the decisions announced from the bench that day to be read in order of increasing importance.
[9] With several cases laying forth the criteria necessary to respect the due process and property rights of individuals, and statements of what constituted an appropriate delegation of legislative powers to the U.S. President, Congress quickly revised the Agricultural Adjustment Act (AAA);[10] however, New Deal supporters still wondered how the AAA would fare against Chief Justice Hughes's restrictive view of the Commerce Clause from the Schechter decision.
On what became known as White Monday, on March 29, 1937, the Court handed down three decisions upholding New Deal legislation, two of them unanimous: West Coast Hotel Co. v. Parrish,[11] Wright v. Vinton Branch,[12] and Virginia Railway v.
Contested in this case was the National Industrial Recovery Act, Section 9(c), in which Congress had delegated to the President authority "to prohibit the transportation in interstate and foreign commerce of petroleum ... produced or withdrawn from storage in excess of the amount permitted ... by any State law".
Two small, independent oil producers, Panama Refining Co. and Amazon Petroleum Co. filed suit seeking an injunction to halt enforcement, arguing that the law exceeded Congress's interstate commerce power and improperly delegated authority to the President.
The Supreme Court, by an 8-1 margin,[9] agreed with the oil companies, finding that Congress had inappropriately delegated its regulatory power without both a clear statement of policy and the establishment of a specific set of standards by which the President was empowered to act.
Although a loss for the Roosevelt administration and New Deal supporters, it was mitigated by the narrowness of the Court's opinion, which did not deny Congress's authority to regulate interstate oil commerce.
A month later, the President issued Executive Order 6102, confiscating all gold coins, bullion, and certificates, requiring they be surrendered to the government by May 1, 1933, in exchange for currency.
[27] On May 6, 1935, Justice Roberts's 5–4 opinion for the Court rejected the government's position, dismissing the purported effect on railway safety as "without support in reason or common sense".
Roberts characterized the provision as "a naked appropriation of private property"—taking the belongings "of one and bestowing it upon another"—and a violation of the Due Process Clause of the Fifth Amendment.
[28] After taking office, President Roosevelt came to believe that William E. Humphrey, a Republican appointed to a six-year term on the Federal Trade Commission (FTC) in 1931, was at odds with the administration's New Deal initiatives.
The basis for his suit was the 1914 Federal Trade Commission Act, which specified that the President was only authorized to remove a FTC commissioner "for inefficiency, neglect of duty, or malfeasance in office".
[32] Further, the act allowed the debtor to remain on the mortgaged property for up to five years after declaring bankruptcy, giving the creditor no opportunity to foreclose immediately.
Chief Justice Hughes delivered the opinion of the unanimous court, holding that Congress had delegated too much lawmaking authority to the President without any clear guidelines or standards.
Thus, the poultry were outside of Congress's authoritative reach unless Schechter's business had a direct and logical connection to interstate commerce, per the Shreveport Rate Case.
[41] Only nine years earlier, in Myers v. United States,[42] the Taft Court had held the President's power to remove executive officials was plenary.
Roosevelt and his entourage viewed Sutherland's particularly vicious criticism as an attempt to publicly shame the President and paint him as having purposefully violated the Constitution.
Officials of the Hoosac Mills Corp. argued that the AAA was as unconstitutional as the National Industrial Recovery Act, attempting to regulate activity not in interstate commerce.
Regarding agriculture as an essentially local activity, the Court invalidated the AAA as a violation of the powers reserved to the states under the Tenth Amendment.
[47] The act, closely following the criteria of the Schechter ruling, declared a public interest in coal production and found it so integrated into interstate commerce as to warrant federal regulation.
Most surprising in the opinion was reliance on 19th-century cases legal scholars had thought long repudiated: Kidd v. Pearson and United States v. E. C. Knight Co.[52][53] On May 25, 1936, the Supreme Court ruled the 1934 Municipal Bankruptcy Act (also known as the Sumners-Wilcox Bill) was unconstitutional in a 5–4 decision.
1, which claimed to be insolvent and unable to meets its debts in the long run, petitioned the local Federal District Court for readjustments granted under the Municipal Bankruptcy Act.
Tipaldo[55] was an important attempt among New Deal supporters to overturn a prior Supreme Court decision prohibiting wage price controls, Adkins v. Children's Hospital.
[56] Felix Frankfurter, who had led the earlier unsuccessful arguments before the Supreme Court, worked carefully to craft the law for the New York legislature so it would stand up to challenges based upon the Adkins opinion.
[57] The case resulted from the indictment of a Brooklyn laundry owner John Tipaldo, who not only had failed to pay his female employees the required minimum salary ($12.40 per week) but had further hidden his transgression by falsifying his books.
Justices Louis Brandeis, Harlan F. Stone, and Benjamin N. Cardozo (the Three Musketeers) each thought Adkins was incorrectly decided and wanted to overturn it.
Justices Willis Van Devanter, James Clark McReynolds, George Sutherland, and Pierce Butler (the Four Horsemen of Reaction) found no distinctions and voted to uphold the habeas corpus petition.
[69] In one of his notes from 1936, Hughes wrote that Roosevelt's re-election forced the Court to depart from "its fortress in public opinion" and severely weakened its capability to base its rulings on personal or political beliefs.
Roberts did prepare a short memorandum discussing his alleged change of stance around the time of the Court-packing effort, which he left in the hands of Justice Felix Frankfurter.