In the United States v. Grimaud case of 1910, the Supreme Court ruled in favor of a law that allowed executive departments to create regulations for public land use. The defendants, Pierre and Isadore Grimaud, were charged with violating rules established by the Secretary of Agriculture regarding grazing sheep on forest reserve lands without a permit. They argued that Congress had unconstitutionally delegated its legislative power to an executive department by allowing it to establish such rules. However, the court disagreed and upheld their conviction stating that when Congress provides general provisions in laws (like protecting public lands), it can allow those who administer such laws (in this case, Department of Agriculture) to prescribe detailed regulations within those boundaries set by Congress itself.

In the dissenting opinion for United States v. Grimaud, Justice Harlan argued that Congress had overstepped its constitutional authority by delegating legislative power to an administrative agency - in this case, the Secretary of Agriculture. He contended that while Congress could establish general rules and principles through legislation, it was not within their purview to delegate the creation of specific regulations or penalties to another entity. In his view, allowing such delegation would blur the separation of powers outlined in the Constitution and potentially lead to arbitrary rule-making without proper checks and balances. This decision set a precedent for future cases involving congressional delegation of regulatory power.