Yakus v. United States

1944

Venue: SCOTUS

Facts: Like Sheldon v. Sill, but in a criminal case: the defendants are being prosecuted for violations of the Emergency Price Control Act in federal court, but challenges to the act's validity are exclusively the domain of the Emergency Courts created by the act.

Posture: Convicted in district court, affirmed by 1st Cir.

Issue: Two main issues:
  1. Does the procedure for challenges to the act preclude the defense of invalidity in a criminal prosecution?
  2. If it does, is this a violation of due process?

Holding: Yes, and no. Affirmed.

Rule: Congress can deprive the courts of jurisdiction by regulation, I guess.

Reasoning: Following Lockerty, the statute does deprive the district court of jurisdiction.

There's no right to an injunction-- it's a matter of discretion. The fact that the pathway is codified isn't a violation of due process. This isn't the kind of statute that you have to violate in order to test its validity-- you can go right to the Administrator and complain. And it's within congress's power to criminalize the violation of administrative regulations. There are lots of instances where failure to assert a constitutional right in a timely fashion waives it.


Dicta: Dissents: This unconstitutionally delegates judicial power.

Congress can't require courts to criminally enforce unconstitutional statutes-- that's just an end-run around the rule of law.