National Broadcasting Co. v. United States
| National Broadcasting Co. v. United States | |
|---|---|
|
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| Argued February 10–11, 1943 Decided May 10, 1943 |
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| Full case name | National Broadcasting Company, Incorporated, et al. v. United States, et al.' |
| Citations | 319 U.S. 190 (more)
63 S. Ct. 997; 87 L. Ed. 1344; 1943 U.S. LEXIS 1119; 1 Media L. Rep. 1965
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| Prior history | Appeal from the District Court of the United States for the Southern District of New York |
| Holding | |
| The Federal Communications Commission can issue regulations pertaining to associations between broadcast networks and affiliated stations. | |
| Court membership | |
| Case opinions | |
| Majority | Frankfurter, joined by Stone, Reed, Douglas, Jackson |
| Dissent | Murphy, joined by Roberts |
| Black and Rutledge took no part in the consideration or decision of the case. | |
National Broadcasting Co. v. United States, 319 U.S. 190 (1943), was a case in which the Supreme Court of the United States held on May 10, 1943 that the Federal Communications Commission had the power to issue regulations pertaining to associations between broadcasting networks and their affiliated stations, otherwise known as "chain networks." The case is important in the development of American administrative law.
The scope of authority held by an agency is determined by the agency's organic statute. Where Congress grants an agency the power to maintain and regulate an area guided by the "public interest, convenience, or necessity," such a grant of power can include the regulation of areas not explicitly contemplated by the organic statute, as long as they are within the scope of the purpose of the original statute.
Note: The approach in this case takes a much more expansive approach than the earlier case of ICC v. Cincinnati, New Orleans and Texas Pacific Railway Co. which provided for more limited powers for administrative agencies. Specifically, ICC held that regulative powers must be expressly granted by statute and not implied, while NBC held that the issuance of regulations, though not expressly granted, are an acceptable way for the agency to fulfill its statutory obligations to serve the "public interest, convenience, or necessity."
The FCC established Chain Broadcasting Regulations in 1941, which specifically governed the licensing and content of chain broadcasting stations. NBC sued to enjoin the enforcement of the regulations. The United States District Court for the Southern District of New York dismissed the complaint, ruling for the government, and NBC appealed.
The Supreme Court ultimately affirmed the dismissal of the complaint, ruling that the government had the power to enact and enforce the regulations in question.
The FCC's authority stemmed from its organic statute, the Communications Act of 1934. The Act provided that:
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