Panama Refining Co. v. Ryan
Encyclopedia
Panama Refining Co. v. Ryan, 293 U.S. 388
(1935), also known as the Hot Oil case, was a case in which the United States Supreme Court
ruled unconstitutional the Roosevelt Administration's prohibition of interstate and foreign trade in petroleum
goods produced in excess of state quotas—the "hot oil" orders adopted under the 1933 National Industrial Recovery Act
.
The ruling was the first of several which overturned key elements of the Administration's New Deal
legislative program. The relevant section 9(c) of the NIRA was found to be an unconstitutional delegation of legislative power in that it permitted Presidential interdiction of trade without defining criteria for the application of the proposed restriction.
The finding thus differed from later Court rulings which argued that Federal government action affecting intrastate production breached the Commerce Clause
of the Constitution
: in Panama v. Ryan Court found that Congress had violated the nondelegation doctrine by vesting the President with legislative powers without clear guidelines, giving the President enormous and unchecked powers. The omission of Congressional guidance on State petroleum production ceilings occasioned the adverse ruling because this omission allowed the executive to assume the role of the legislature. Justice Cardozo
dissented, claiming that the guidelines had been sufficient.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1935), also known as the Hot Oil case, was a case in which the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
ruled unconstitutional the Roosevelt Administration's prohibition of interstate and foreign trade in petroleum
Petroleum
Petroleum or crude oil is a naturally occurring, flammable liquid consisting of a complex mixture of hydrocarbons of various molecular weights and other liquid organic compounds, that are found in geologic formations beneath the Earth's surface. Petroleum is recovered mostly through oil drilling...
goods produced in excess of state quotas—the "hot oil" orders adopted under the 1933 National Industrial Recovery Act
National Industrial Recovery Act
The National Industrial Recovery Act , officially known as the Act of June 16, 1933 The National Industrial Recovery Act (NIRA), officially known as the Act of June 16, 1933 The National Industrial Recovery Act (NIRA), officially known as the Act of June 16, 1933 (Ch. 90, 48 Stat. 195, formerly...
.
The ruling was the first of several which overturned key elements of the Administration's New Deal
New Deal
The New Deal was a series of economic programs implemented in the United States between 1933 and 1936. They were passed by the U.S. Congress during the first term of President Franklin D. Roosevelt. The programs were Roosevelt's responses to the Great Depression, and focused on what historians call...
legislative program. The relevant section 9(c) of the NIRA was found to be an unconstitutional delegation of legislative power in that it permitted Presidential interdiction of trade without defining criteria for the application of the proposed restriction.
The finding thus differed from later Court rulings which argued that Federal government action affecting intrastate production breached the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
of the Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
: in Panama v. Ryan Court found that Congress had violated the nondelegation doctrine by vesting the President with legislative powers without clear guidelines, giving the President enormous and unchecked powers. The omission of Congressional guidance on State petroleum production ceilings occasioned the adverse ruling because this omission allowed the executive to assume the role of the legislature. Justice Cardozo
Benjamin N. Cardozo
Benjamin Nathan Cardozo was a well-known American lawyer and associate Supreme Court Justice. Cardozo is remembered for his significant influence on the development of American common law in the 20th century, in addition to his modesty, philosophy, and vivid prose style...
dissented, claiming that the guidelines had been sufficient.