## Facts

- Congress enacted the Economic Stabilization Act of 1970, authorizing the President to issue orders and regulations to stabilize prices, rents, wages, and salaries to control inflation.
- The President implemented the statute through Executive Order 11615, imposing a 90-day freeze on prices, rents, wages, and salaries at levels tied to a pre–August 15, 1971 base period.
- A labor union sued federal officials responsible for administering the stabilization program and major meat-packing employers that were parties to collective bargaining agreements with the union.
- The union sought to enforce a negotiated 25-cent-per-hour wage increase scheduled to take effect during the freeze period; employers asserted that implementing the increase would violate the Executive Order.
- The union also challenged the statute and executive actions as unconstitutional, arguing that Congress granted the President overly broad discretion without adequate standards.

## Issues

1. Whether the Economic Stabilization Act of 1970 unconstitutionally delegated legislative power to the President by authorizing broad wage and price controls without sufficiently definite standards.
2. Whether the wage-price freeze could lawfully be applied to prevent implementation of a wage increase required by existing collective bargaining agreements.
3. Whether injunctive relief should issue to bar enforcement of the stabilization program as applied to the union and employers.

## Decision

- The three-judge district court denied the requested injunction.
- The court upheld the Economic Stabilization Act’s delegation of authority as constitutional.
- The court sustained the validity of the Executive Order and implementing administration of the stabilization program.
- The court accepted that the freeze could temporarily bar implementation of the scheduled contractual wage increase during the freeze period.

## Legal Principles

- A delegation of broad regulatory authority may be upheld when statutory purpose, context, and program structure supply an intelligible principle sufficient to guide executive action.
- In evaluating delegations in emergency economic regulation, courts may allow greater flexibility given the complexity and rapid change of inflationary conditions.
- Executive implementation through regulations and guidelines can function as a legal constraint on the exercise of delegated discretion, supporting the conclusion that discretion is not unlimited.
- A generally applicable, time-limited wage stabilization measure may lawfully affect performance of existing wage obligations during the freeze period when authorized by a valid federal stabilization statute.

## Conclusion

The court sustained Congress’s broad grant of stabilization authority and refused to enjoin the federal wage-price freeze, holding that the statute provided sufficient direction when read in light of its inflation-control purpose, the stabilization program’s nature, and the executive branch’s binding implementation rules, and that the temporary restraint on the bargained-for wage increase did not justify injunctive relief.


Amalgamated Meat Cutters & Butcher Workmen of N. Am., AFL-CIO v. Connally, 337 F. Supp. 737 (D.D.C. 1971)