Understanding Different Types of Courts and the Doctrine of Powers through Federal Radio Commission v. General Electric Co., 281 U.S. 464 (1930)
There are those that say that there are no Article III courts. Well, anyone that says this you should automatically know that they do not understand the constitution. A lot of professed ‘teachers” that , claim to teach the constitution, absolutely lack the knowledge they profess.
Each Article of the Constitution of the United States has its own court. Each of those types of courts have separate and distinct rules. There is Article I Courts or Legislative Courts. There is Article II Courts or Administrative Courts. Then there is Article III Courts or Judicial Courts.
Introduction:
The case of Federal Radio Commission v. General Electric Co. in 1930 not only shaped the regulation of the radio industry but also provides a unique lens through which to explore the diverse types of courts within the American legal system. In addition, this case underscores the fundamental principles of the separation of powers and delegation of powers doctrines, which are integral to the U.S. legal framework.
1. Article III Courts and the Separation of Powers Doctrine:
The one Article III court, Supreme Court of the United States, and federal district courts, stand at the pinnacle of the federal judiciary. These courts are established under Article I, II, and/or III of the U.S. Constitution and play a crucial role in upholding the separation of powers doctrine. This doctrine mandates that the legislative, executive, and judicial branches of government remain separate and distinct, with each branch having defined roles and responsibilities. Article III courts are the guardians of this separation, ensuring that laws passed by Congress are consistent with the Constitution and that executive actions adhere to the law.
Now, let’s look at a part of this case. In the section cited here you can see the separation between the three different types of courts;
In the cases just cited, as also in others, it is recognized that the courts of the District of Columbia are not created under the judiciary article of the Constitution but are legislative courts, and therefore that Congress may invest them with jurisdiction of appeals and proceedings such as have been just described. But this court cannot be invested with jurisdiction of that character, whether for purposes of review or otherwise. It was brought into being by the judiciary article of the Constitution, is invested with judicial power only, and can have no jurisdiction other than of cases and controversies falling within the classes enumerated in that article. It cannot give decisions which are merely advisory; nor can it exercise or participate in the exercise of functions which are essentially legislative or administrative. Keller v. Potomac Electric Power Co., supra, page 444, of 261 U. S., 43 S. Ct. 445, 67 L. Ed. 731, and cases cited; Postum Cereal Co. v. California Fig Nut Company, supra, pages 700-701 of 272 U. S. 47 S. Ct. 284, 71 L. Ed. 478; Liberty Warehouse Co. v. Grannis, 273 U. S. 70, 74, 47 S. 282, 71 L. Ed. 541; Willing v. Chicago Auditorium Association, 277 U. S. 274, 289, 48 S. Ct. 507, 72 L. Ed. 880; Ex parte Bakelite Corporation, 279 U. S. 438, 449, 49 S. Ct. 411, 73 L. Ed. 789.
You can see in the above paragraph that there are three types of courts. The Supreme Court was created by Article III of the constitution. Then it mentions legislative and administrative courts, which are created under the powers granted by the Constitution to Congress.
2. Legislative Courts and the Delegation of Powers Doctrine:
Legislative courts, although not directly involved in the Federal Radio Commission v. General Electric Co. case, are established by Congress under its legislative powers. This establishment exemplifies the delegation of powers doctrine. This doctrine allows Congress to delegate certain powers to administrative agencies and legislative courts, provided that the delegation is made clear and specific. Legislative courts, such as the Court of Appeals for the Federal Circuit, operate within the bounds of powers delegated by Congress. This principle ensures that specialized issues, like patent disputes, can be addressed effectively by entities with expertise in those areas.
This is where the Legislature had the power to create a second supreme court called the United States Supreme Court starting under the Judiciary Act of 1789. If people understood the Constitution, when they here about the “Supreme Court” handling an appeal then you should know that it is not under Article III it is under the Judiciary Act. Article 1 section 8 Clause 9 states; “To constitute Tribunals inferior to the supreme Court;” That includes creating an inferior Supreme Court. As mentioned above under Delegation of Powers Doctrine, Congress can create these inferior tribunals and delegate those powers to the Executive branch which created the Article II courts called administrative courts.
3. Administrative Courts and the Intersection of Separation and Delegation of Powers:
Administrative courts, as seen in the case of the Federal Radio Commission (FRC), are at the intersection of the separation of powers and delegation of powers doctrines. They are part of the executive branch, responsible for implementing and enforcing regulations, yet they also hold quasi-judicial functions. Administrative law judges within these agencies preside over cases, ensuring compliance with the laws and regulations they administer. The delegation of powers doctrine permits Congress to delegate authority to these agencies, but the separation of powers doctrine requires that their functions remain distinct from the core judicial branch.
Jurisdictions:
– Article III courts, with their broad jurisdiction, serve as the ultimate arbiters of constitutional and federal law disputes, ensuring that the principles of separation of powers are upheld.
– Legislative courts, established through congressional delegation, deal with specialized areas of law while adhering to the delegation of powers doctrine.
– Administrative courts, like those within the FRC, operate within their delegated authority, striking a balance between executive and quasi-judicial functions, underlining the complex interplay between separation and delegation of powers.
Conclusion:
Federal Radio Commission v. General Electric Co. not only sheds light on different types of courts within the American legal system but also illustrates how the doctrines of separation of powers and delegation of powers are vital in shaping the roles and responsibilities of these courts. Understanding these doctrines is essential for appreciating the intricacies of the U.S. legal landscape and the delicate balance between the branches of government that underpin it.
To read the case click here Federal Radio Commission v. General Electric Co., 281 U.S. 464 (1930)
