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Frances PerkinsFrances Perkins
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what they were doing, kept in touch with Richberg, sort of knew what was going on and many times conferred with me over the telephone or in person about the method by which they were doing things. He was disturbed, as I was, about the great number of codes in small and relatively unimportant industries which they were taking up.

I cite all this only as an indication of the difficulty with which the President, as President, could keep control of that particular kind of a function and keep any kind of intelligent knowledge or direction of it in his own hands. It wasn't only because it was Hugh Johnson. It was because of the complexity of the operation itself and because of its utter newness. There were no precedents for anything of the sort. The rules of administrative law were not very well laid down.

It was sometime after NRA had disappeared that the Supreme Court handed down a decision in which it made very bitter, but in a way very proper, comments upon the irregular procedures in some administrative law operation. I remember at the time saying to myself, “I'm glad that I insisted on some of these open procedures, the public hearings, the notifications of all those concerned as to what it was proposed to do, a lapse of time before the actual adoption of the regulation which was supposed to be





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