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In the 1935 case Morgan et al. v. United States et al., the U.S. Supreme Court ruled that a group of Louisiana slaughterhouse operators were not given due process during hearings held by the Secretary of Agriculture to determine fair rates for their services under the Packers and Stockyards Act of 1921. The court found that because they had no opportunity to cross-examine witnesses or present evidence, their Fifth Amendment rights were violated. This decision established an important precedent regarding administrative law, asserting that individuals have a right to be heard in any proceeding which could potentially deprive them of property or livelihood.
In the dissenting opinion for Morgan et al. v. United States et al., Justice McReynolds argued that the majority's decision to uphold a regulation by the Secretary of Agriculture setting rates for stockyard services was an overreach of executive power and violated due process rights. He contended that Congress did not have authority to delegate its legislative powers to an administrative agency, in this case, the Secretary of Agriculture, without providing clear standards or guidelines on how those powers should be exercised. Furthermore, he believed that allowing such delegation would undermine separation of powers principles and lead to arbitrary rule-making by unelected officials with no accountability or oversight from elected representatives in Congress. Additionally, Justice McReynolds expressed concern about procedural fairness as he felt there was insufficient opportunity given for affected parties (stockyard operators) to present evidence and challenge decisions made by administrative agencies under these regulations.