Sangamon Valley Television Corp. v. United States
United States Court of Appeals for the District of Columbia Circuit
269 F.2d 221 (1959)
The FCC ran a notice-and-comment rulemaking to decide whether to award a television license to Sangamon Valley Television (Sangamon) (plaintiff) in Springfield, Illinois, or to Signal Hill (defendant) in St. Louis. After the comment period closed, Signal Hill's president met privately with FCC commissioners and separately wrote each of them letters advocating for St. Louis based on projected higher viewership -- none of which was entered into the formal record. The FCC ultimately awarded the license to Signal Hill, and Sangamon challenged the order.
Whether ex parte communications in a notice-and-comment rulemaking can invalidate the proceeding when it resolves conflicting private claims in a manner similar to an adjudication.