United States v. Corrick

Background

Operators of market agencies at the Chicago stockyards posted a new schedule of rates on October 19, 1935, to take effect November 1, 1935, and tendered that schedule to the Secretary of Agriculture. The Secretary refused to receive it because he had already issued orders in January and March 1934 fixing rates and because litigation over those orders was pending. The agencies then sued in federal district court seeking a temporary injunction to prevent prosecution for charging their new rates, and the district court granted that injunction.

Reasoning

The Court reviewed only whether the district court abused its discretion in issuing the temporary injunction. It held the district court did not have the power to hear the suit because the Packers and Stockyards Act and related statutes set a specific process for changing or challenging Secretary orders and did not allow relief for a mere refusal to accept a schedule. The Court explained that the Act requires filing and public notice for rate schedules, and that after investigation and a hearing the Secretary may set the lawful rates; those rates remain in force until the Secretary or a proper court changes them. Because the Secretary had fixed rates after a hearing, the district court lacked authority to bar prosecutions for charging different rates, and lack of that authority cannot be waived by the parties.

Real world impact

As a practical matter, market agencies at the Chicago stockyards cannot override Secretary-fixed rates by posting their own schedules, and they risk prosecution if they charge different rates. Federal district courts must follow the statutory process and may not enjoin prosecutions when the statute assigns rate-fixing authority to the Secretary. The Supreme Court reversed the injunction and directed the lower court to dismiss the suit.