Humphrey’s Executor v. United States
E192996
Humphrey’s Executor v. United States is a 1935 U.S. Supreme Court case that limited the president’s power to remove officials of independent regulatory agencies, reinforcing their insulation from direct executive control.
All labels observed (3)
| Label | Occurrences |
|---|---|
| Humphrey’s Executor v. United States canonical | 3 |
| Humphrey's Executor v. United States | 1 |
| Humphrey’s Executor, Petitioner v. United States | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T1740761 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Humphrey’s Executor v. United States Context triple: [Tenure of Office Act, influencedDecision, Humphrey’s Executor v. United States]
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A.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
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B.
Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
-
C.
Nixon v. Fitzgerald
Nixon v. Fitzgerald is a 1982 U.S. Supreme Court case that established absolute immunity from civil damages liability for a President’s official acts.
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D.
United States v. Butler
United States v. Butler was a 1936 U.S. Supreme Court case that struck down key provisions of the New Deal’s Agricultural Adjustment Act as an unconstitutional use of federal taxing and spending power.
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E.
United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Humphrey’s Executor v. United States Target entity description: Humphrey’s Executor v. United States is a 1935 U.S. Supreme Court case that limited the president’s power to remove officials of independent regulatory agencies, reinforcing their insulation from direct executive control.
-
A.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
-
B.
Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
-
C.
Nixon v. Fitzgerald
Nixon v. Fitzgerald is a 1982 U.S. Supreme Court case that established absolute immunity from civil damages liability for a President’s official acts.
-
D.
United States v. Butler
United States v. Butler was a 1936 U.S. Supreme Court case that struck down key provisions of the New Deal’s Agricultural Adjustment Act as an unconstitutional use of federal taxing and spending power.
-
E.
United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
administrative law case ⓘ separation of powers case ⓘ |
| appliesTo |
independent regulatory agencies
ⓘ
officers with fixed terms and for-cause removal protections ⓘ |
| aroseFrom | President Franklin D. Roosevelt’s attempt to remove FTC Commissioner William E. Humphrey ⓘ |
| concernsOffice | Federal Trade Commission ⓘ |
| concernsOfficial | FTC commissioner ⓘ |
| concernsPresident |
President Franklin D. Roosevelt
ⓘ
surface form:
Franklin D. Roosevelt
|
| distinguishedFrom | Myers v. United States ⓘ |
| hasChiefJustice | Charles Evans Hughes ⓘ |
| hasCitation | 295 U.S. 602 ⓘ |
| hasConstitutionalProvision | Article II of the United States Constitution ⓘ |
| hasConstitutionalTheme |
checks and balances
ⓘ
scope of executive power ⓘ |
| hasCountry |
United States of America
ⓘ
surface form:
United States
|
| hasCourt | Supreme Court of the United States ⓘ |
| hasDecisionDate | May 27, 1935 ⓘ |
| hasDecisionType | unanimous decision ⓘ |
| hasDecisionYear | 1935 ⓘ |
| hasEra |
New Deal
ⓘ
surface form:
New Deal era
|
| hasFullCaseName |
Humphrey’s Executor v. United States
self-linksurface differs
ⓘ
surface form:
Humphrey’s Executor, Petitioner v. United States
|
| hasJurisdiction |
United States government
ⓘ
surface form:
federal government of the United States
|
| hasLanguage | English ⓘ |
| hasLegalIssue |
independence of regulatory commissions
ⓘ
presidential removal power ⓘ separation of powers between branches of government ⓘ |
| hasOpinionAuthor | Charles Evans Hughes ⓘ |
| hasPetitioner | Humphrey’s Executor ⓘ |
| hasRespondent |
United States of America
ⓘ
surface form:
United States
|
| hasStatuteInvolved |
Federal Trade Commission Act of 1914
ⓘ
surface form:
Federal Trade Commission Act
|
| hasSubjectMatter |
administrative agencies
ⓘ
public law ⓘ |
| hasVote | 9–0 ⓘ |
| held |
Congress may limit the President’s power to remove officers of independent regulatory agencies to specified causes such as inefficiency, neglect of duty, or malfeasance in office.
ⓘ
Members of certain independent regulatory commissions are not purely executive officers subject to at-will presidential removal. ⓘ Federal Trade Commission ⓘ
surface form:
The Federal Trade Commission performs quasi-legislative and quasi-judicial functions and is not subject to full presidential control.
The President may not remove a commissioner of an independent regulatory commission except for the causes specified by Congress in the statute creating the commission. ⓘ |
| isCitedIn |
Free Enterprise Fund v. Public Company Accounting Oversight Board
ⓘ
Morrison v. Olson ⓘ Seila Law LLC v. Consumer Financial Protection Bureau ⓘ |
| isKeyPrecedentFor |
cases on removal protections for independent agency officials
ⓘ
modern administrative state structure ⓘ |
| limited | Myers v. United States ⓘ |
| reinforcedDoctrine |
congressional power to create independent agencies insulated from direct presidential removal
ⓘ
independence of administrative agencies ⓘ |
| resultedIn | limitation on presidential power to remove members of independent commissions ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Humphrey’s Executor v. United States Description of subject: Humphrey’s Executor v. United States is a 1935 U.S. Supreme Court case that limited the president’s power to remove officials of independent regulatory agencies, reinforcing their insulation from direct executive control.
Referenced by (5)
Full triples — surface form annotated when it differs from this entity's canonical label.
United States Supreme Court cases of the Hughes Court
→
includesCase
→
Humphrey’s Executor v. United States
ⓘ
Humphrey’s Executor v. United States
→
hasFullCaseName
→
Humphrey’s Executor v. United States
self-linksurface differs
ⓘ
this entity surface form:
Humphrey’s Executor, Petitioner v. United States
this entity surface form:
Humphrey's Executor v. United States