Amalgamated Meat Cutters v. Connally
Encyclopedia
Amalgamated Meat Cutters
Amalgamated Meat Cutters
The Amalgamated Meat Cutters , officially the Amalgamated Meat Cutters and Butcher Workmen of North America, was a labor union that represented retail butchers and packinghouse workers.-History:...

 v. Connally
, 337 F.Supp. 737 (1971) is a court case decided by the United States District Court for the District of Columbia
United States District Court for the District of Columbia
The United States District Court for the District of Columbia is a federal district court. Appeals from the District are taken to the United States Court of Appeals for the District of Columbia Circuit The United States District Court for the District of Columbia (in case citations, D.D.C.) is a...

 relating to the limits of the nondelegation doctrine
Nondelegation doctrine
The doctrine of nondelegation describes the theory that one branch of government must not authorize another entity to exercise the power or function which it is constitutionally authorized to exercise itself. It is explicit or implicit in all written constitutions that impose a strict structural...

. The district court upheld the delegation of legislative power to the executive branch that was contained in the Economic Stabilization Act. Even though the Act gave a broad grant of legislative power (what opponents called a "blank check"), the court reasoned that discretion of the executive branch would be limited by:
  1. The "broad equity standard inherent in a stabilization program" (i.e. the norms of rule of law and the history and tradition of executive regulation of the economy)
  2. The practice of "self-narrowing." Specifically, the court believed that once the executive branch developed standards for exercising its discretion, it would be bound by those standards it had previously set.


Federal Courts accepted the principle of self-narrowing for about thirty years. In Whitman v. American Trucking Associations, Inc.
Whitman v. American Trucking Associations, Inc.
Whitman v. American Trucking Associations, Inc., , was a case decided by the United States Supreme Court in which the Environmental Protection Agency's National Ambient Air Quality Standard for regulating ozone and particulate matter was challenged by the American Trucking Association along with...

(2001), however, the United States Supreme Court, in a decision written by Justice Scalia
Antonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...

, specifically overturned the principle of self-narrowing, arguing that "[t]he very choice of which portion of power to exercise ... would itself be an exercise of the forbidden legislative authority." [emphasis original] In both decisions, however, the courts ultimately upheld the grant of discretionary power, thus indicating the continued weakness of the nondelegation doctrine.
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