Bowles v. Willingham
Annotate this Case
321 U.S. 503 (1944)
U.S. Supreme Court
Bowles v. Willingham, 321 U.S. 503 (1944)
Bowles v. Willingham
Argued January 7, 10, 1944
Decided March 27, 1944
321 U.S. 503
l. Under § 205(a) of the Emergency Price Control Act of 1942 and § 24(1) of the Judicial Code, and in view of § 204(d) of the Act, a federal district court, in a suit by the Administrator, has authority to enjoin a proceeding in a state court to restrain issuance by the Administrator of rent orders, and § 265 of the Judicial Code, forbidding federal courts to enjoin proceedings in state courts, is inapplicable. P. 321 U. S. 510.
(a) Congress may determine whether the federal courts should have exclusive jurisdiction of controversies which arise under the Constitution and laws of the United States and which are therefore within the judicial power of the United States as defined in Art. III, § 2 of the Constitution, or whether they should exercise that jurisdiction concurrently with the courts of the States. P. 321 U. S. 511.
(b) The authority of Congress to withhold from state courts all jurisdiction of controversies arising under the Constitution and laws of the United States includes the power to restrict the occasions when that jurisdiction may be invoked. P. 321 U. S. 512.
2. By the rent control provisions of the Emergency Price Control Act of 1942, authorizing the Price Administrator to fix maximum rents for housing accommodations in defense rental areas, Congress did not delegate its legislative power. Yakus v. United States, ante, p. 321 U. S. 414. P. 321 U. S. 514.
The standards prescribed by the Act are adequate for the judicial review which is afforded. The fact that there is a one for the exercise of discretion by the Administrator is no more fatal here than in other situations where Congress has prescribed the general standard and has left to an administrative agency the determination of the precise situations to which the provisions of the Act will be applied and the weight to be accorded various statutory criteria on given facts.
3. The requirement that the maximum rent or rents established by the Administrator be "generally" fair and equitable, § 2(b), does not render the Act violative of the Fifth Amendment. P. 321 U. S. 516.
(a) That price-fixing is on a class basis, rather than on an individual basis, does not render it invalid. P. 321 U. S. 518.
(b) The restraints imposed on the national government in this regard by the Fifth Amendment are no greater than those imposed on the States by the Fourteenth. P. 321 U. S. 518.
(c) Congress was dealing here with conditions created by activities resulting from a great war effort; it was under no constitutional necessity of providing a system of price control which would assure each landlord a "fair return" on his property. P. 321 U. S. 519.
(d) And though the legislation may have reduced the value of the property being regulated, there was no "taking" of it. P. 321 U. S. 517.
4. That landlords are not afforded a hearing before the order or regulation fixing rents becomes effective does not render the Act violative of the Fifth Amendment. Provision for judicial review after the order or regulation become effective satisfies the requirements of due process under these circumstances. P. 321 U. S. 519.
5. Questions as to the validity of orders or regulations issued pursuant to the Act may be considered only by the Emergency Court of Appeals on the review provided by § 204. P. 321 U. S. 521.
Direct appeal from an order of the District Court dismissing a suit by the Price Administrator on the ground of the unconstitutionality of the rent provisions of the Emergency Price Control Act of 1942 and regulations promulgated pursuant thereto.
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