Panama Refining Co. V Ryan

Panama v. Ryan; Amazon v.
Ryan
Page 1 of 2
U.S. Supreme Court

Panama Refining Co. v. Ryan, 293 US 388 (1935)
293 U.S. 388
Panama Refining Co. et al

v.
Ryan et al.
Amazon Petroleum Corporation et al.

v.
Same.
Nos. 135, 260.

Argued Dec. 10, 11, 1934.
Decided Jan. 7, 1935.
FACTS:
 Historical background:
o One of the economic problems caused by the Great Depression was
faltering oil prices. This was due to overproduction and a general
economic slowdown.
o The oil industry sought Congressional intervention to control the situation.
 President issued Executive Order 6199 on July 11, 1933, banning interstate oil
shipments if the oil was produced in excess of state quotas.
o Basis for this EO was section 9(c) of title 1 of the National Industrial
Recovery Act, which authorizes the President to prohibit transportation of
excess oil and prescribes punishment of a fine, imprisonment, or both.
 President issued Executive Order 6204 on July 14, 1933, authorizing the
Secretary of the Interior to exercise authority as vested in the President in
enforcing section 9(c) and EO 6199.
 Secretary of the Interior issued regulations to carry out EO 6199 and 6204 on
July 15, 1933.
o Regulation IV: Every producer of petroleum should file a monthly
statement giving information on the company and oil production.
o Regulation V: Every purchaser/shipper/refiner of petroleum should file a
monthly statement giving information on the company and oil production.
o Regulation VII: Aforementioned should keep adequate books and records
of all transactions involving the production and transportation of petroleum
and petroleum products.
 Further EOs:
o President issued “Petroleum Code” (Code of Fair Competition for the
Petroleum Industry) on August 19, 1933 regulating the production of
petroleum as deemed necessary by each state’s requirement.
Case Digest by P.D. Zuniga 1-Eeee

Panama v. Ryan; Amazon v. Ryan
Page 2 of 2
o President issued an EO on August 28, 1933 designating the Sec. of the

Interior as the Administrator and the Department of the Interior as the
federal agency, to exercise on behalf of the President all powers vested in
him under that Act and Code.
 The Panama Refining Co. and the Amazon Petroleum Corp. pressed suits on
October 1933 to restrain the defendants (federal officials) from enforcing the
restrictions on the production and disposition of oil.
 Court of three judges denied injunction and dismissed the bill as against the
defendants.
 District Judge granted a permanent injunction.
 Circuit Court of Appeals reversed decrees against the federal officials and
directed that the bills be dismissed.
 Cases came to the Supreme Court on writs of certiorari.
ISSUE:
Whether or not certain regulatory measures (EO 6199, 6204, and regulations) have
constitutional validity.
RULING:
EO 6199, 6204 and the regulations issued by the Sec. of the Interior are without
constitutional authority.
In trying to regulate the transportation of oil production in excess of state permission,

“the Congress has declared no policy, has established no standard, has laid down no
rule. There is no requirement, no definition of circumstances and conditions in which the
transportation is to be allowed or prohibited.”
Congress had failed to provide a “primary standard” to guide the executive branch. This
oversight allowed the president to act as he pleased rather than within an administrative
role.
This gives the President “unlimited authority to determine the policy… as he may see fit.
And disobedience to his order is made a crime punishable by fine and imprisonment.”
This “hot oil” provision was seen as an unconstitutional delegation of legislative powers
to the executive branch, thus violating the doctrine of separation of powers.
RATIO:
From the U.S. Constitution:
Article 1
Section 1. All legislative powers herein granted shall be vested in a Congress of the
United States, which shall consist of a Senate and House of Representatives.
Case Digest by P.D. Zuniga 1-Eeee

Panama Refining Co. V Ryan

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Panama v. Ryan; Amazon v.

U.S. Supreme Court

Panama Refining Co. et al

Amazon Petroleum Corporation et al.

Nos. 135, 260.

Case Digest by P.D. Zuniga 1-Eeee

o President issued an EO on August 28, 1933 designating the Sec. of the

In trying to regulate the transportation of oil production in excess of state permission,

From the U.S. Constitution:

Case Digest by P.D. Zuniga 1-Eeee

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