both cases. Roberts's opinion for the court in Nebbia was also encouraging for the administration: Nebbia also holds a particular significance: it was the one case in which the Court abandoned its jurisprudential distinction between the "public" and "private" spheres of economic activity, an essential distinction in the court's analysis of state police power. The effect of this decision radiated outward, affecting other doctrinal methods of analysis in wage regulation, labor, and the power of the U.S. Congress to regulate commerce. Black Monday Just three weeks after its defeat in the railroad pension case, the Roosevelt administration suffered its most severe setback, on May 27, 1935: "Black Monday". Chief Justice Hughes arranged for the decisions announced from the bench that day to be read in order of increasing importance. The Supreme Court ruled unanimously against Roosevelt in three cases: Humphrey's Executor v. United States, Louisville Joint Stock Land Bank v. Radford, and Schechter Poultry Corp. v. United States. Further New Deal setbacks With several cases laying forth the criteria necessary to respect the due process and property rights of individuals, and statements of what constituted an appropriate delegation of legislative powers to the President, Congress quickly revised the Agricultural Adjustment Act (AAA). However, New Deal supporters still wondered how the AAA would fare against Chief Justice Hughes's restrictive view of the Commerce Clause from the Schechter decision. Antecedents to reform legislation The coming conflict with the court was foreshadowed by a 1932 campaign statement Roosevelt made: An April 1933 letter to the president offered the idea of packing the Court: "If the Supreme Court's membership could be increased to twelve, without too much trouble, perhaps the Constitution would be found to be quite elastic." The next month, soon-to-be Republican National Chairman Henry P. Fletcher expressed his concern: "[A]n administration as fully in control as this one can pack it [the Supreme Court] as easily as an English government can pack the House of Lords." Searching out solutions As early as the autumn 1933, Roosevelt had begun anticipation of reforming a federal judiciary composed of a stark majority of Republican appointees at all levels. Roosevelt tasked Attorney General Homer Cummings with a year-long "legislative project of great importance". Justice Department lawyers then commenced research on the "secret project", with Cummings devoting what time he could. The focus of the research was directed at restricting or removing the Supreme Court's power of