TLS as president, one page, 7 x 8.75, White House letterhead, May 27, 1935. FDR writes to H. L. Smyser in Louisville. In full: “Many thanks for your fine letter of May twenty-third. It was very kind of you to send it. I am especially pleased to know of your approval of the message….” On the same day, the Supreme Court declared the NIRA [National Industrial Recovery Administration], one of the key elements of FDR’s New Deal, unconstitutional. The Act, which had established a government agency to promote fair competition and price supports, was widely viewed as too complex and difficult to enforce; the Supreme Court decreed that it infringed upon states’ rights and extended legislative powers to the executive branch in violation of the Nondelegation doctrine of the Constitution. Accompanied by the original mailing envelope. Light toning (more prominent at edges) a few faint spots of foxing, and mild handling wear, otherwise fine condition. Auction LOA John Reznikoff/PSA/DNA and R&R COA.