United States v. Grimaud

220 U.S. 506 (1911)

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United States v. Grimaud

United States Supreme Court
220 U.S. 506 (1911)

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Facts

In 1897, Congress authorized the Department of the Interior to manage forest reserves under the Forest Service Organic Administration Act (Act). Congress transferred this administrative power to the Department of Agriculture in 1905, creating the United States Forest Service (USFS). The USFS began to regulate uses of the national forests that had previously been tolerated. Pierre Grimaud (defendant) did not obtain a permit to graze his sheep on the Sierra Forest Reserve as required by the USFS. As a result, Grimaud was charged with unauthorized pasturage. Grimaud challenged the constitutionality of Congress’s delegation of rulemaking authority to the Department of Agriculture and USFS. The circuit court dismissed in favor of Grimaud. The United States Supreme Court granted a writ of error.

Rule of Law

Issue

Holding and Reasoning (Lamar, J.)

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