Until the decision by the court, it was held by the General Assembly that it could delegate and revoke executive authority at will.

The state of Indiana has historically had a weak executive branch and a strong legislature, from its original state constitution and the restrictions placed on the office by the anti-governor faction in the constitutional convention, which resented the powers of the territorial governors.

[1] The governorship remained a weak position until the American Civil War, when the governor suppressed the legislature and took on unconstitutional powers.

The situation continued until 1933, when the Democratic-controlled legislature passed the Executive Reorganization Act to grant to governor expansive powers over the burgeoning Great Depression government bureaucracy.

The court created, for the first time, a legal basis for the governor to assume power in areas previously delegated to other officials.