Krielow v. Louisiana Department of Agriculture and Forestry

Louisiana passed a law allowing an assessment of up to three cents per hundredweight on rice production, but only if the state's rice producers themselves approved it by majority vote; the legislature retained no authority to review either the producers' votes or their chosen assessment amount within that cap. The stated purpose was funding research programs to promote the rice industry. Roughly 40 rice producers (plaintiffs) sued the Louisiana Department of Agriculture and Forestry (defendant), challenging the law's constitutionality; the agency argued the producers' vote was merely implementing the legislature's law rather than an unlawful delegation of lawmaking power. The district court found the law facially unconstitutional in part, and the agency appealed.