(Peters & Woolley). After the enactment of this act, union membership drastically increased. Due to the rapid increase of union member, the National Recovery Administration (NRA) was established to oversee the drafting and the implementation of fair competition codes. The NRA established and implemented a multitude of codes, which become confusing to business. There were so many codes that business would frequently confuse them or the codes were conflicting with other, which resulted in businesses paying different wages to their employees. The NRA was well received by unions and business, until the mass confusion with the codes began; their popularity began to dwindle fast. Due to the lack of popularity and several lawsuits, the U.S. Supreme Court declared the NIRA unconstitutional in May 1935. The Court held that the act impermissibly delegated legislative power to the NRA and that the application of the act to commerce within the state exceeded the powers granted to the federal government by the Commerce Clause. (The Commerce Clause gives Congress the power to regulate commerce between states, but not within an individual state). (Peters