Facts
- Congress authorized creation and management of federal forest reservations and allowed their use only for lawful purposes subject to rules and regulations.
- Under this authority, the Secretary of Agriculture issued regulations requiring permits (and related charges) to graze sheep on the Sierra Forest Reserve in California.
- Pierre Grimaud and other stockmen grazed sheep on the reserve without obtaining the required permits.
- The defendants were indicted for pasturing sheep on a forest reservation without the permit required by the Secretary’s regulations.
- The defendants did not dispute the unpermitted grazing; they argued the regulatory scheme was unconstitutional because it let the Secretary effectively define criminal conduct.
Issues
- Whether Congress unconstitutionally delegated legislative power by authorizing the Secretary of Agriculture to issue binding regulations governing use of forest reservations, including grazing-permit requirements.
- Whether Congress may impose criminal penalties for violating agency regulations when Congress sets the penalty by statute but leaves specific operational details to the agency.
Decision
- The Supreme Court reversed the district court’s dismissal of the indictments.
- The Court held that Congress may authorize an executive officer to make administrative rules to carry out statutory objectives and to supply operational details.
- The Court held that properly issued regulations under the forest-reserve statutes have the force of law.
- The Court held that criminal punishment for violating such regulations is constitutional when Congress has made violations punishable and has fixed the penalty by statute.
- The Court recognized authority to require charges for use of forest-reserve resources as part of the statutory administrative scheme.
Legal Principles
- Congress may not delegate legislative power, but it may delegate authority to make administrative rules implementing a statutory policy and supplying details.
- Agency regulations can have the force of law when issued under valid statutory authorization.
- When Congress provides by statute that violations of valid regulations are offenses and prescribes the penalty, Congress (not the agency) defines the crime and fixes the punishment.
- Use of federal property subject to statutory regulations may be conditioned on compliance with permit systems; any prior informal tolerance of unregulated use may be curtailed by Congress.
Conclusion
The Court upheld the forest-reserve statutory scheme, ruling that Congress permissibly empowered the Secretary of Agriculture to issue grazing-permit regulations and that violations could be criminally punished because Congress, by statute, authorized enforcement and set the penalty while the agency supplied administrative details.