Humphrey's v. United States

Background

A family member sued the United States to recover salary owed to William E. Humphrey, a Federal Trade Commission member whom President Roosevelt removed in October 1933. Humphrey had been appointed and confirmed in 1931 for a seven-year term running to 1938, refused to resign when asked, and died in 1934. The Court of Claims certified two questions asking whether the FTC Act limits the President’s power to remove a commissioner to specific causes and, if so, whether that restriction is constitutional.

Reasoning

The Court focused on the statute’s language, the lawmaker debates, and the commission’s role. It held that the FTC’s fixed term and removal-for-cause language show Congress intended to protect commissioners from removal except for inefficiency, neglect, or malfeasance. The opinion distinguished earlier decisions about purely executive officers (like a postmaster) and explained that the commission performs mostly quasi-judicial and quasi-legislative work, so broad presidential removal power would undermine its independence. The Court therefore answered both certified questions “Yes”: the statute limits removal to the stated causes, and that limit is constitutional.

Real world impact

The decision protects the job security and independence of FTC commissioners and similar regulatory or adjudicative officials while they serve their terms. It narrows the reach of a prior case that supported broad removal power for purely executive subordinates, making clear that Congress may insulate certain agencies from at-will presidential removal. The ruling signals that members of independent commissions can be kept free from immediate presidential control while carrying out quasi-judicial or legislative functions.

Dissents or concurrances

Justice McReynolds agreed with the answers; no dissenting opinion is presented in the certified questions.