Humphrey's Executor v. United States

PETITIONER: Humphrey's Executor
RESPONDENT: United States
LOCATION:

DOCKET NO.: 667
DECIDED BY: Hughes Court (1932-1937)
LOWER COURT:

ARGUED: May 01, 1935
DECIDED: May 27, 1935

Facts of the case

President Hoover appointed, and the Senate confirmed, Humphrey as a commissioner of the Federal Trade Commission (FTC). In 1933, President Roosevelt asked for Humphrey's resignation since the latter was a conservative and had jurisdiction over many of Roosevelt's New Deal policies. When Humphrey refused to resign, Roosevelt fired him because of his policy positions. However, the FTC Act only allowed a president to remove a commissioner for "inefficiency, neglect of duty, or malfeasance in office." Since Humphrey died shortly after being dismissed, his executor sued to recover Humphrey's lost salary.

Question

Did section 1 of the Federal Trade Commission Act unconstitutionally interfere with the executive power of the President?