Merriam believed that part of the success or failure of the National Planning Board's proposals depended on the administrative capacity of the executive branch to adopt and push for the recommended policies. Therefore, Merriam began lobbying President Roosevelt for a commission to study the structure and functions of the executive. Roosevelt was very receptive to the idea. The Supreme Court had struck down the National Industrial Recovery Act (a key legislative accomplishment of the New Deal) in "Schechter Poultry Corp. v. United States", 295 U.S. 495 (1935), and significantly limited the president's power to remove members of independent executive agencies in "Panama Refining Co. v. Ryan", 293 U.S. 388 (1935). Merriam assured the president that if he established a committee to review the administration of the executive branch, the committee's report could be written in such a way as to justify the president's reorganization goals while couching them in the neutral language of academic research. On March 22, 1936, Roosevelt established the Committee on Administrative Management (commonly known as the Brownlow Committee) and charged it with developing proposals for reorganizing the executive branch. Besides himself, the three-person committee consisted of Louis Brownlow, and Luther Gulick. On January 10, 1937, the committee released its report. Famously declaring "The President needs help," the committee's report advocated a strong chief executive, including among its 37 recommendations significant expansion of the presidential staff, integration of managerial agencies into a single presidential office, expansion of the merit system, integration of all independent agencies into existing Cabinet departments, and modernization of federal accounting and financial practices.