PANAMA REFINING CO. V. RYAN
293 U.S. 338 (1935)
NATURE OF THE CASE: This was a dispute over the constitutionality of the President
issuing executive orders under an act of Congress.
FACTS: The President, by Executive Order, prohibited the transportation in interstate and
foreign commerce of petroleum and the products thereof produced or withdrawn from storage in
excess of the amount permitted to be produced or withdrawn from storage by any State law or
valid regulation. That order was made under 10(a) of the National Industrial Recovery Act
authorizing the President 'to prescribe such rules and regulations as may be necessary to
carry out the purposes' of the Act. More orders were issued and more and different
regulations were made and eventually these suits were brought. Panama Refining Company (P)
sued to restrain the defendants, who were federal officials, from enforcing Regulations as
prescribed by the Secretary of the Interior under 9(c) of the Act. Ps claimed that 9(c)
as an unconstitutional delegation to the President of legislative power and as transcending
the authority of the Congress under the commerce clause. Amazon Petroleum Corporation (P)
not only attacked 9(c) and its regulations but challenged the validity of provisions of
the Petroleum Code. A court of three judges was convened. That court decided that the cause
of action against the federal officials for the consideration of the District Judge alone.
The parties agreed that the causes of action should be severed and that each cause should be
submitted to the tribunal having jurisdiction of it. The court sustaining the state orders,
denied injunction, and dismissed the bill as against the state authorities. In both cases
against the federal officials, a permanent injunction was granted. The Circuit Court of
Appeals reversed the decrees against the federal officials and directed that the bills be
dismissed.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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