Grimaud and some other people
were letting their sheep graze in the Sierra Forest Reserve without a
permit. They were fined. They appealed.
The Forestry Reserve Act (30 Stat. 35) authorized the Secretary of Agriculture to
make regulations about the use of Forest Reserves.
Grimaud argued that the Forestry
Reserve Act was unconstitutional
because it was an impermissible delegation of authority (aka a violation
of the Non-Delegation Doctrine).
Basically, the Non-Delegation
Doctrine says that only Congress is
empowered to write laws, the Executive Branch cannot write laws. So
Congress is forbidden from giving an Executive Branch Agency (like USDA)
the power to write laws.
See Yakus v. United
States (321 U.S. 414 (1944)).
The Trial Court dismissed the
case. The US appealed.
The Appellate Court affirmed.
The US appealed.
The US Supreme Court reversed
and found the Forestry Reserve Act
constitutional.
The US Supreme Court found
that it would be impractical for Congress to provide general regulations
for grazing rights, and therefore it is within their power to confer that
power to an Administrative Agency (in this case USDA).
The Court found that Congress
may delegate the power to "fill up details" where it has
indicated its will in the Statute, and it may make violations of such
regulations punishable as indicated in the Statute.
The Court noted that
Congress cannot delegate legislative power to an Administrative Agency.
Basically, this case said that
it would be impractical for Congress to set all the little nitpicky rules
and regulations that are required. So, they are allowed to set broad
policies (aka intelligible principles),
and allow an Administrative Agency to write the specific regulations and
come up with the details.
See the later case of Whitman
v. American Trucking Ass'n (531 U.S.
457 (2001)), which upheld the Clean Air Act's broad delegation of authority to the EPA to
set air quality standards.
