Panama Refining Co. v. Ryan

Panama Refining Co. v. Ryan, 293 U.S. 388 (1935), also known as the Hot Oil case, was a case in which the US Supreme Court ruled that the Franklin 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 (NIRA), was unconstitutional.

Panama Refining Co. v. Ryan
Supreme Court of the United States
Argued December 10–11, 1934 Decided January 7, 1935
Full case name	Panama Refining Co., et al. v. Ryan, et al.
Citations	293 U.S. 388 (more) 55 S. Ct. 241; 79 L. Ed. 446; 1935 U.S. LEXIS 251
Holding
Specific parameters must be laid down in the delegation of power to the President to enforce legislative statutes.
Court membership
Chief Justice Charles E. Hughes Associate Justices Willis Van Devanter · James C. McReynolds Louis Brandeis · George Sutherland Pierce Butler · Harlan F. Stone Owen Roberts · Benjamin N. Cardozo
Case opinions
Majority	Hughes, joined by Van Devanter, McReynolds, Brandeis, Sutherland, Butler, Stone, Roberts
Dissent	Cardozo

The ruling was the first of several that 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, as it permitted presidential interdiction of trade without defining criteria for the application of the proposed restriction.

The finding thus differed from later rulings that argued that federal government action affecting intrastate production breached the Commerce Clause of the Constitution. In Panama v. Ryan, the Court found that Congress had violated the nondelegation doctrine by vesting the President with legislative powers without clear guidelines and by giving the President enormous and unchecked powers. The omission of congressional guidance on state petroleum production ceilings occasioned the adverse ruling because it allowed the executive to assume the role of the legislature.

Justice Cardozo dissented and claimed that the guidelines had been sufficient.

See also

• Connally Hot Oil Act of 1935

Further reading

• Hart, James (1942). "Limits of Legislative Delegation". Annals of the American Academy of Political and Social Science. 221: 87–100. doi:10.1177/000271624222100114. JSTOR 1023967. S2CID 144182838.
• Larkin, John Day (1937). "The Trade Agreement Act in Court and in Congress". American Political Science Review. 31 (3): 498–507. doi:10.2307/1948168. JSTOR 1948168. S2CID 146981948.

External links

• Text of Panama Refining Co. v. Ryan, 293 U.S. 388 (1935) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress