Sunday, May 12, 2013

Panama Refining Co. v. Ryan case brief

Panama Refining Co. v. Ryan case brief
293 U.S. 388, 55 S. Ct. 241, 79 L. Ed. 446 (1935)

CASE SYNOPSIS: The United States Supreme Court granted certiorari to review decrees of the Circuit Court of Appeals for the Fifth Circuit, which reversed decrees of a district court enjoining defendants, federal officials, from enforcing certain executive orders and regulations. Plaintiffs, oil producers, challenged the constitutionality of 15 U.S.C.S. § 709(c) and the executive orders and regulations made under it.


  • The Court reversed decrees and remanded causes with direction to modify the decrees so as to grant permanent injunctions restraining the federal officials from enforcing certain orders and regulations against the oil producers based on § 9(c) of Title I of the National Industrial Recovery Act of June 16, 1933, 15 U.S.C.S. § 709(c).
  • The Court noted that there were limits of delegation for which there was no constitutional authority to transcend.
  • Here, § 9(c) was found to go beyond those limits. 
  • As to the transportation of oil production in excess of state permission, Congress had declared no policy, had established no standard, and had laid down no rule. 
  • There was no requirement or definition of circumstances and conditions in which the transportation of petroleum was to be allowed or prohibited. 
  • Furthermore, the Court found another objection to the validity of the prohibition laid down by executive orders under § 9(c) in that the executive orders contained no finding or statement of the grounds of the President's action in enacting the prohibition. 
  • Accordingly, the executive orders and the regulations issued thereunder were without constitutional authority.

CONCLUSION: The Court reversed the decrees of the circuit court of appeals and remanded the causes to a federal district court with directions to modify its decrees so as to grant permanent injunctions restraining defendants from enforcing the specified executive orders and regulations.

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