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Administrative Law Keyed to Schwartz
Stark v. Wickard
Citation:
321 U.S. 288 (1944)Facts
The Agricultural Marketing Agreement Act of 1937 authorized the Secretary of Agriculture to regulate milk marketing by establishing minimum prices based on milk’s utilization (Class I for fluid milk, Class II for manufacturing). To avoid inequities among producers, the Act provided for a “uniform” or “blended” price to be paid to all producers regardless of how their milk was ultimately used. The Secretary’s Order No. 4 for the Greater Boston area implemented this system but also authorized deductions from producer payments to fund payments to cooperative associations. The petitioners, who were not members of cooperatives, challenged these deductions as unauthorized by the Act. They alleged that the Secretary exceeded his statutory authority by directing the market administrator to deduct funds from producer payments to compensate cooperatives, effectively reducing the minimum price they received for their milk. The government argued that producers had no standing to challenge the order because the Act did not explicitly grant them judicial review rights.
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