United States v. Grimaud
United States Supreme Court
220 U.S. 506 (1911)
Congress authorized the Department of the Interior, and later the newly created U.S. Forest Service (USFS), to manage national forest reserves, and the USFS began regulating land uses like grazing that had previously gone unregulated. Pierre Grimaud (defendant) grazed sheep on the Sierra Forest Reserve without obtaining the permit the USFS's regulations required, and was charged with unauthorized pasturage. Grimaud challenged the constitutionality of Congress's delegation of rulemaking power to the Department of Agriculture and USFS, and the circuit court ruled in his favor; the government sought Supreme Court review.
Whether Congress may constitutionally delegate authority to the United States Forest Service to make administrative rules concerning public lands and punish violations of those rules as a public offense.