''Panama Refining Co. v. Ryan'', 293 U.S. 388 (1935), also known as the ''Hot Oil case'', was a case, in which the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

ruled that the

Franklin Roosevelt administration Franklin Delano Roosevelt (; ; January 30, 1882April 12, 1945), often referred to by his initials FDR, was an American politician and attorney who served as the 32nd president of the United States from 1933 until his death in 1945. As the ...

's prohibition of interstate and foreign trade in

petroleum Petroleum, also known as crude oil, or simply oil, is a naturally occurring yellowish-black liquid mixture of mainly hydrocarbons, and is found in geological formations. The name ''petroleum'' covers both naturally occurring unprocessed crud ...

goods produced in excess of state

quota Quota may refer to: Economics * Import quota, a trade restriction on the quantity of goods imported into a country * Market Sharing Quota, an economic system used in Canadian agriculture * Milk quota, a quota on milk production in Europe * Indi ...

s, the "hot oil" orders adopted under the 1933

National Industrial Recovery Act The National Industrial Recovery Act of 1933 (NIRA) was a US labor law and consumer law passed by the 73rd US Congress to authorize the president to regulate industry for fair wages and prices that would stimulate economic recovery. It also e ...

(NIRA), was unconstitutional. The ruling was the first of several that overturned key elements of the administration's

New Deal The New Deal was a series of programs, public work projects, financial reforms, and regulations enacted by President Franklin D. Roosevelt in the United States between 1933 and 1939. Major federal programs agencies included the Civilian Cons ...

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 The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and amon ...

of the

Constitution A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of Legal entity, entity and commonly determine how that entity is to be governed. When ...

; in ''Panama v. Ryan'', the Court found that Congress had violated the

nondelegation doctrine The doctrine of nondelegation (or non-delegation principle) is the theory that one branch of government must not authorize another entity to exercise the power or function which it is constitutionally authorized to exercise itself. It is explicit ...

by vesting the President with legislative powers without clear guidelines and 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 Cardozo is a Portuguese and Spanish surname. It is an archaic spelling of the surname "Cardoso (surname), Cardoso". Notable people with this surname *Aaron Cardozo (1762–1834), Gibraltarian consul for Tunis and Algiers *Albert Cardozo (1828–18 ...

dissented and claimed that the guidelines had been sufficient.

External links

* United States Constitution Article One case law United States Supreme Court cases of the Hughes Court United States Commerce Clause case law United States energy case law 1935 in United States case law United States nondelegation doctrine case law History of the petroleum industry in the United States United States Supreme Court cases {{SCOTUS-stub

See also

Further reading

External links