National Broadcasting Co. v. United States, 319 U.S. 190 (1943), was a United States Supreme Court case in which the Court held that the Federal Communications Commission had the power to issue regulations pertaining to associations between broadcasting networks and their affiliated stations, otherwise known as "chain networks." The case is important in the development of American administrative law. Legal principles The scope of authority held by an agency is determined by the agency's organic statute. Where Congress grants an agency the power to maintain and regulate an area guided by the "public interest, convenience, or necessity," such a grant of power can include the regulation of areas not explicitly contemplated by the organic statute, as long as they are within the scope of the purpose of the original statute. Note: The approach in this case takes a much more expansive approach than the earlier case of ICC v. Cincinnati, New Orleans and Texas Pacific Railway Co. which provided for more limited powers for administrative agencies. Specifically, ICC held that regulative powers must be expressly granted by statute and not implied, while NBC held that the issuance of regulations, though not expressly granted, are an acceptable way for the agency to fulfill its statutory obligations to serve the "public interest, convenience, or necessity." Facts and procedural posture The FCC established Chain Broadcasting Regulations in 1941, which specifically governed the licensing and content of chain broadcasting stations. NBC sued to enjoin the enforcement of the regulations. The United States District Court for the Southern District of New York dismissed the complaint, ruling for the government, and NBC appealed. The Supreme Court ultimately affirmed the dismissal of the complaint, ruling that the government had the power to enact and enforce the regulations in question. Analysis The FCC's authority stemmed from its organic statute, the Communications Act of 1934. The Act provided that: It is the purpose of this Act, among other things, to maintain the control of the United States over all the channels of interstate and foreign radio transmission; and to provide for the use of such channels, but not the ownership thereof, by persons for limited periods of time, under licenses granted by Federal authority, and no such license shall be construed to create any right, beyond the terms, conditions, and periods of the license. The Act also provided that the criterion governing the exercise of the Commission's license power