Light v. United States
220 U.S. 523 (1911)

  • Light's cattle wandered onto the Holy Cross Forest Reserve. Since he didn't have a permit to allow his cattle to graze on the Federal property, he was fined. He appealed.
    • The Forestry Reserve Act (30 Stat. 35) authorized the Secretary of Agriculture to make regulations about the use of Forest Reserves.
    • Light argued that there was a Colorado law that provided that a landowner could not recover damages for trespass unless the property was enclosed with a fence. Light argued that since there was no fence to stop his cows from entering the Forest Reserve, he shouldn't have to pay the fine.
    • Light also argued that public lands are held in trust for the people, and so the proclamation creating the Forest Reserve without the consent of Colorado was not in the 'public trust'.
    • Light also argued that the US had historically allowed people to graze on Federal property, so they were estopped from ending the practice now.
    • Light also argued that the Forestry Reserve Act was unconstitutional because it was an impermissible delegation of authority (aka a violation of the Non-Delegation Doctrine).
      • Basically, the Non-Delegation Doctrine says that only Congress is empowered to write laws, the Executive Branch cannot write laws. So Congress is forbidden from giving an Executive Branch Agency (like USDA) the power to write laws.
      • See United States v. Grimaud (220 U.S. 506 (1911)).
  • The Trial Court upheld the fine. Light appealed.
  • The Appellate Court upheld the fine. Light appealed.
  • The US Supreme Court upheld the fine.
    • The US Supreme Court found that Light had intentionally sent his cattle onto the Forest Reserve, and the Colorado law was only applicable to accidental trespass.
    • The Court found that Congress has power to set apart portions of the public domain and establish them as Forest Reserves and to prohibit the grazing of cattle thereon or to permit it subject to rules and regulations.
      • Even without the consent of the State government.
      • The Federal government has the power to change the rules and invoke any implied license that may have existed in the past.
    • The Court found that Congress is allowed to authorize the Secretary of Agriculture to make provisions for the protection against destruction by fire and depredations of the public forest and forest reservations, and to "make such rules and regulations and establish such service as will insure the objects of such reservations, namely to regulate their occupancy and use and to preserve the forests thereon from destruction."
      • Basically, the Court was saying that it would be impractical for Congress to set all the little nitpicky rules and regulations that are required. So, they are allowed to set broad policies (aka intelligible principles), and allow an Administrative Agency to write the specific regulations and come up with the details.