Note 767 — Chapter X · JUDICIAL REVIEW

Scores of examples of such action can be gleaned from the studies cited above, and the dissenting opinion of Chief Justice Vinson in the Steel Seizure cases, op. cit., at 667-710. E.g., Lincoln directed the payment of unappropriated funds from the treasury to private individuals, in clear violation of Article I, Sec. 9, Cl. 7 of the Constitution. In patent disregard of Article I, Sec. 8, Cl. 12, delegating to Congress the power “to raise and support armies,” he increased the strength of the Army and Navy by presidential proclamation. Binkley, op. cit., pp. 111-14. Corwin has pointed to many administrative agencies established by President Roosevelt without prior legislative sanction (Total War and the Constitution, op. cit., pp. 50-52) and has alleged that the transfer of destroyers to Britain directly violated “at least two statutes and represented an exercise by the President of a power which by the Constitution is specifically assigned to Congress.” (The President: Office and Powers, op. cit., p. 289; 4th ed., 1957, p. 238).