New York
How A.L.A. Schechter Poultry Corp. v. United States applies in New York: state-specific rules, key cases, and bar exam notes for Administrative Law.
New York courts follow the principles established in A.L.A. Schechter Poultry Corp. by closely scrutinizing legislative delegations of power to administrative agencies. The courts seek to ensure that such delegations do not violate constitutional safeguards regarding separation of powers and the non-delegation doctrine.
New York law requires that any delegation of legislative power to administrative agencies must be accompanied by an intelligible principle to guide the exercise of that power, consistent with the non-delegation doctrine outlined in A.L.A. Schechter.
The court affirmed that the Dental Board had exceeded its authority by legislating instead of merely enforcing statutory provisions.
The court invalidated a rule that lacked clear guidelines, emphasizing the necessity of an intelligible principle as dictated by Schechter.
The court clarified that agencies must operate within bounds set by enabling legislation, following the non-delegation principle.
New York's approach mirrors the federal standard in that both systems require legislative clarity in delegating authority to administrative agencies. However, New York courts may enforce the non-delegation doctrine more stringently than certain federal interpretations post-New Deal, where more leeway has sometimes been granted.
The principles from A.L.A. Schechter are often tested in New York bar exams, particularly in sections covering administrative law and the non-delegation doctrine.