YAKUS v. UNITED STATES 321 U.S. 414 (1944)

The EMERGENCY PRICE CONTROL ACT of 1942 delegated power to fix prices and rents to the Office of Price Administration (OPA). Under the act, challenges to the legality of OPA regulations could not be made in federal district court enforcement proceedings, even those aimed at imposing criminal penalties, but must be made in separate proceedings in the EMERGENCY COURT OF APPEALS. The Supreme Court sustained this limitation on the district courts in civil enforcement proceedings in Lockerty v. Phillips (1944). In Yakus, the Court upheld the limitation in the context of a criminal prosecution. The Court also rejected attacks on the act as an unconstitutional DELEGATION OF POWER for failing to provide sufficient guidelines. Chief Justice HARLAN FISKE STONE, for the Court, said that the act contained specific objectives: "to stabilize prices and to prevent speculative, unwarranted and abnormal increases in prices and rents." It also mentioned standards for price-setting: administrators should consult industry and consider current prices. Because the act accorded with earlier decisions and because its standards were "sufficiently definite and precise," Stone could find no unauthorized delegation of power. Justice OWEN ROBERTS, dissenting, believed that the case presented substantially the same issue as SCHECHTER POULTRY CORPORATION V. UNITED STATES (1935) which the majority, he said, had clearly overruled. Justice WILEY RUTLEDGE also dissented, joined by Justice FRANK MURPHY. Rutledge argued that Congress could not constitutionally command the federal courts to enforce administrative orders, disregarding their possible unconstitutionality. The Rutledge view seems likely to prevail in the absence of a wartime emergency.