In 1935, the Supreme Court decision in "Schecter Poultry Corporation v. United States" invalidated regulations of the poultry industry according to the nondelegation doctrine and as an invalid use of Congress's power under the commerce clause. The unanimous decision rendered unconstitutional the National Industrial Recovery Act, a main component of President Franklin Roosevelt's New Deal. Again in 1936, in "Carter v. Carter Coal Company", the Supreme Court struck down a key element of the New Deal's regulation of the mining industry on the grounds that mining was not "commerce." In the preceding decades, the Court had struck down a laundry list of progressive legislation: minimum-wage laws, child labor laws, agricultural relief laws, and virtually every other element of the New Deal legislation that had come before it. After winning re-election in 1936, Roosevelt proposed the Judicial Procedures Reform Bill of 1937 to allow the President to appoint an additional Justice for each sitting Justice over age 70. Given the age of the current Justices, that would allow a Supreme Court of up to 15 Justices. Roosevelt claimed that to be intended to lessen the load on the older Justices, rather than an attempt to achieve a majority that would cease to strike his New Deal acts.