Lehigh Valley Cooperative Farmers, Inc. v. United States (1961)

Docket
79
Decided
1961-01-01
Category
General

Summary

Question: Were the “compensatory payment” provisions that the Secretary of Agriculture enacted valid under the Agricultural Market Agreement Act of 1937? Conclusion: The compensatory payment provisions were invalid as inconsistent with Congress’ intent in enacting the Agricultural Market Agreement Act of 1937. Justice John M. Harlan, II delivered the opinion of the 6-1 majority. The Court held the Secretary of Agriculture exceeded his authority by creating the “compensatory payment” provisions of the Agricultural Marketing Act of 1937. The provisions essentially forced non-regional milk producers to subsidize regional milk producers, which interfered with the competitive advantage the the cheaper, non-regional milk producers would naturally have. The legislative history of the Act indicates that Congress intended it to prevent this type of creation of economic barriers to protect the prices of regional products. Therefore, the provisions conflicted with Congress’ intent and were invalid. Justice Hugo L. Black wrote a dissent in which he argued that the Court should have affirmed the lower court’s decision upholding the Secretary of Agriculture. Black explained that the Secretary did not overreach, and he should be given the authority to impose the provisions at issue in order to protect farmers.

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