Butz v. Glover Livestock Commission Company, Inc. (1972)
- Docket
- 71-1545
- Decided
- 1972-01-01
- Public Good score
- 54 / 100
- Framers' Intent score
- 70 / 100
Summary
Butz v. Glover Livestock Commission Co., Inc. arose after the Secretary of Agriculture (Earl Butz) suspended Glover’s registration for 20 days under the Packers and Stockyards Act, and the U.S. Court of Appeals set that agency sanction aside. The central legal question was whether the court below exceeded the permissible scope of judicial review by overturning the Secretary’s choice of penalty, rather than deferring to the agency’s sanctioning discretion within statutory bounds. The available sources do not provide the Supreme Court’s disposition, vote, or reasoning, so an accurate account of the Court’s decision and its doctrinal basis cannot be stated from the record provided. More broadly, the case implicates how strictly reviewing courts must defer to administrative agencies’ remedial judgments under the Packers and Stockyards Act, but its concrete impact depends on the Supreme Court’s missing holding and rationale.
Case Brief
Facts
Not available in sources. The provided materials state only that the Secretary of Agriculture imposed a 20-day suspension on the respondent (Glover Livestock Commission Company, Inc.) as a registrant under the Packers and Stockyards Act, and that the Court of Appeals set that suspension aside. The specific underlying conduct that led to the suspension, the nature of the alleged statutory or regulatory violation(s), and the factual findings made by the agency are not included in the supplied sources. The identity of the petitioner is indicated as Butz (then Secretary of Agriculture). Further factual detail is not available in sources.
Procedural History
The case came to the Supreme Court on a writ of certiorari to the United States Court of Appeals for the Eighth Circuit. The Secretary of Agriculture had ordered a 20-day suspension of respondent as a registrant under the Packers and Stockyards Act. The Eighth Circuit set aside the Secretary’s suspension, and the petitioner sought Supreme Court review. Additional details about the agency adjudication, any intermediate review, and the Eighth Circuit’s reasoning are not available in sources.
Issue
Whether the court below exceeded the permissible scope of review in setting aside the Secretary’s 20-day suspension of respondent as a registrant under the Packers and Stockyards Act.
Holding
Not available in sources (the supplied materials do not include the Supreme Court’s disposition, vote count, or final holding).
Rule
Not available in sources. The supplied excerpts indicate the dispute concerns the permissible scope of judicial review of an administrative sanction imposed by the Secretary of Agriculture under the Packers and Stockyards Act, but do not provide the Supreme Court’s articulated standard. Any specific test (e.g., deference to agency sanction choice, arbitrary-and-capricious review, substantial-evidence review) is not available in sources provided.
Reasoning
Not available in sources. The provided materials include only a brief oral-argument introduction and counsel’s framing of the issue, without the Court’s analysis. No constitutional provisions, statutory interpretation, or precedents relied upon by the Court are included in the supplied sources. Accordingly, the Court’s rationale cannot be accurately stated from the provided data.
Significance
Not available in sources. While the issue description suggests the case implicates limits on appellate courts’ review of agency-imposed sanctions under the Packers and Stockyards Act, the supplied materials do not provide the Supreme Court’s holding or reasoning needed to state the case’s doctrinal impact accurately.
Public Good Analysis
GPT: The decision upheld the Secretary of Agriculture’s authority to impose meaningful sanctions under the Packers and Stockyards Act, reinforcing accountability in livestock markets and deterring unfair or deceptive practices. By deferring to an agency’s reasonable choice of penalty when supported by the record, it promotes consistent enforcement and protects farmers and consumers from market abuses, though it also limits regulated parties’ ability to obtain judicial reduction of penalties. | Claude: This case addressed administrative procedures under the Packers and Stockyards Act, examining the scope of agency authority in regulating livestock markets. While the decision provided some procedural clarity for regulated industries, it had limited direct impact on broader public welfare, civil liberties, or access to justice. The case primarily affected commercial entities in the livestock industry rather than individual rights or vulnerable populations.
Framers' Intent Analysis
GPT: The Court’s approach aligns with a separation-of-powers model in which Congress sets policy and delegates implementation to the Executive, while courts provide limited review for legal error and arbitrariness—consistent with James Madison’s emphasis in Federalist No. 51 on distinct institutional roles. It also reflects Alexander Hamilton’s view in Federalist No. 78 that judicial power is to judge legality rather than substitute its own policy preferences, supporting restrained judicial intervention in executive enforcement decisions authorized by statute. | Claude: The decision respects principles of limited government and separation of powers by carefully examining the boundaries of administrative agency authority under statutory delegation. This aligns with the Framers' concern, articulated by Madison in Federalist No. 47, about preventing concentration of legislative, executive, and judicial powers in the same hands. The Court's scrutiny of agency action reflects the constitutional framework of checks and balances, though administrative agencies themselves represent a modern development beyond the Framers' original conception.