Springer v. Government of the Philippine Islands; Agoncillo v. Same

Summary

The Court affirmed judgments ousting directors of two Philippine government-controlled corporations because the Philippine Legislature could not assign executive functions—voting government-owned stock and selecting corporate directors—to legislative officers. The Organic Act vested executive functions in the Governor-General or under his supervision, and its specific enumeration of appointment powers did not displace that broader grant. Justice Holmes, joined by Justice Brandeis, would have upheld the legislation on the ground that managing stock in private corporations was not an executive governmental function; Justice McReynolds would have resolved only the narrower basis necessary to invalidate the legislation.