Light's cattle wandered onto
the Holy Cross Forest Reserve. Since he didn't have a permit to allow his
cattle to graze on the Federal property, he was fined. He appealed.
The Forestry Reserve Act (30 Stat. 35) authorized the Secretary of Agriculture to
make regulations about the use of Forest Reserves.
Light argued that there was
a Colorado law that provided that a landowner could not recover damages
for trespass unless the property was enclosed with a fence. Light argued
that since there was no fence to stop his cows from entering the Forest
Reserve, he shouldn't have to pay the fine.
Light also argued that
public lands are held in trust for the people, and so the proclamation
creating the Forest Reserve without the consent of Colorado was not in
the 'public trust'.
Light also argued that the
US had historically allowed people to graze on Federal property, so they
were estopped from ending the practice now.
Light also 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 United States v.
Grimaud (220 U.S. 506 (1911)).
The Trial Court upheld the
fine. Light appealed.
The Appellate Court upheld the
fine. Light appealed.
The US Supreme Court upheld
the fine.
The US Supreme Court found
that Light had intentionally sent his cattle onto the Forest Reserve, and
the Colorado law was only applicable to accidental trespass.
The Court found that
Congress has power to set apart portions of the public domain and
establish them as Forest Reserves and to prohibit the grazing of cattle
thereon or to permit it subject to rules and regulations.
Even without the consent of
the State government.
The Federal government has
the power to change the rules and invoke any implied license that may
have existed in the past.
The Court found that
Congress is allowed to authorize the Secretary of Agriculture to make
provisions for the protection against destruction by fire and
depredations of the public forest and forest reservations, and to
"make such rules and regulations and establish such service as will
insure the objects of such reservations, namely to regulate their
occupancy and use and to preserve the forests thereon from
destruction."
Basically, the Court was saying
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.
