Humphrey's Executor v. United States
Case Date: 05/19/2024
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Humphrey's Executor v. United States, 295 U.S. 602 (1935), was a United States Supreme Court case decided during the Franklin Delano Roosevelt presidency, regarding the powers that a President of the United States has to remove certain executive officials of a "quasi-legislative," "quasi-judicial" administrative body created by Congress, for purely political reasons and without the consent of Congress.
Roosevelt was dissatisfied with William Humphrey, a member of the Federal Trade Commission, as Humphrey did not, in Roosevelt's view, support his New Deal policies vigorously enough.[1]
Initially and a second time, Roosevelt requested Humphrey to resign from the FTC – requests to which Humphrey did not yield. The third time, Roosevelt fired Humphrey, writing "[e]ffective as of this date you are hereby removed from the office of Commissioner of the Federal Trade Commission." Nevertheless, Humphrey continued to come to work at the FTC even after he was formally fired.[1] However, the Federal Trade Commission Act only permitted the President to dismiss an FTC member for "inefficiency, neglect of duty, or malfeasance in office." Roosevelt's decision to dismiss Humphrey was based solely on political differences, rather than job performance or alleged acts of malfeasance.
The case went to the Supreme Court, but Humphrey died before the case could be decided. The case was then pursued by the executors of his estate; thus, the case obtained the title "Humphrey's Executor".
The Court distinguished between executive officers and quasi-legislative or quasi-judicial officers. The latter may be removed only with procedures consistent with statutory conditions enacted by Congress; the former serve at the pleasure of the President and may be removed at his discretion. The Court ruled that the Federal Trade Commission was a quasi-legislative body because of other powers it had, and therefore the President could not fire an FTC member solely for political reasons; thus, Humphrey's firing was improper.
U.S. Attorney General Robert H. Jackson, later to join the Supreme Court himself, said in his memoirs that Roosevelt was particularly annoyed by the Court's decision, as the President felt that it had been rendered for spite.
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