United States v. Curtiss-Wright Export Corp. Case Brief Summary | Law Case Explained

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United States v. Curtiss-Wright Export Corp. | 299 U.S. 304 (1936)

The Constitution assigns certain powers and duties to each of the three branches of government. Only Congress has the power to make laws, and Congress isn’t allowed to give its lawmaking powers away to the president, the courts, or anyone else. This principle, called the nondelegation doctrine, is essential to maintaining the separation of powers between the three branches of government.

In the landmark case of United States v. Curtiss-Wright, the United States Supreme Court had to decide just how much discretion Congress could allow the president without crossing the line that separates the legislative powers from the executive and violating the nondelegation doctrine.

The events of this case started in 1932, when the countries of Bolivia and Paraguay began a border war over an arid scrubland region called the Chaco Boreal. The conflict, known as the Chaco War, claimed more than 100,000 lives over the course of three years.

Both Bolivia and Paraguay had to import all the guns and ammunition used in the war, because they didn’t have their own weapons manufacturers.

On May 28, 1934, to encourage a ceasefire, the United States Congress passed a joint resolution outlawing the sale of weapons to countries involved in the Chaco War. But this resolution specified the ban would only go into effect if the American president issued a proclamation stating that halting the sale of weapons would promote peace in the region. President Franklin Roosevelt activated the ban by proclamation that same day. The ban remained in effect until November 14, 1935, when it was revoked by a second presidential proclamation.

During the ban, Curtiss-Wright Export Corporation, a weapons manufacturer, conspired to sell fifteen machine guns to Bolivia. Shortly after the ban was lifted, Curtiss-Wright was indicted in federal district court for selling the weapons. At trial, Curtiss-Wright argued that the ban on weapon sales wasn’t valid, because Congress had delegated its lawmaking powers to the president in violation of the Constitution.

The district court held that Congress improperly delegated its lawmaking powers to the president when it passed the joint resolution, and that the ban was therefore unconstitutional. The government appealed to the Supreme Court.

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