United States v. Morgan

Background

A dealer or manufacturer shipped goods that the Department of Agriculture’s Bureau of Chemistry tested for being adulterated or misbranded under the Pure Food and Drug Act. The law directs the Bureau to analyze samples, requires notice and an opportunity to be heard to the party from whom a sample was taken, and makes the Secretary certify findings to the district attorney, who must then begin prosecutions. The act also treats dealers holding a guaranty differently: a dealer with a guaranty may avoid prosecution while the guarantor can be prosecuted. State health officers may also complain to prosecutors without giving the statutory notice.

Reasoning

The central question was whether the statute’s notice-and-hearing provision prevents prosecutors or grand juries from bringing criminal cases unless that administrative hearing has occurred. The Court explained that the hearing is administrative, voluntary, and not a substitute for criminal proceeding protections; an adverse administrative finding is not binding and a favorable finding is not an acquittal. The text shows notice is required only for the party from whom a sample was taken and was not intended to be jurisdictional. When the Secretary certifies a violation, the district attorney must act without delay, but that obligation does not strip prosecutors or grand juries of their usual power to pursue offenses independently.

Real world impact

The ruling lets criminal prosecutions proceed even where no prior departmental hearing was held, preserves grand juries’ investigative role, and prevents the administrative notice from creating a special immunity. The Court reversed the lower court’s judgment and left district attorneys responsible for prosecuting offenses under the statute.