applicable to Hawaii and the Philippine Islands, the Court enjoined
enforcement of an act of the Territory of Hawaii which prohibited
maintenance of foreign-language schools except upon written permit and
payment of a fee based upon attendance,[166] and held unconstitutional a
Philippine statute which prohibited Chinese merchants from keeping any
accounts in Chinese.[167]

DEPRIVATION OF PROPERTY

Retroactive Legislation Sustained

Federal regulation of future action, based upon rights previously
acquired by the person regulated, is not prohibited by the Constitution.
So long as the Constitution authorizes the subsequently enacted
legislation, the fact that its provisions limit or interfere with
previously acquired rights does not condemn it. Accordingly, rent
regulations were sustained as applied to prevent execution of a judgment
of eviction rendered by a State court before the enabling legislation
was passed.[168] An order by an Area Rent Director reducing an
unapproved rental and requiring the landlord to refund the excess
previously collected, was held, with one dissenting vote, not to be the
type of retroactivity which is condemned by law.[169] The retroactive
effect of a new principle announced by a decision of an administrative
tribunal has been likened to the effect of judicial decisions in cases
of first impression. In Securities Comm'n. _v._ Chenery Corp.,[170] the
Supreme Court sustained a decision of the Commission which refused to
approve a plan of reorganization for a public utility holding company so
long as the preferred stock purchased by the management was treated on a
parity with other preferred stock even though the purchase of such
stock, when made, did not conflict with any law or rule of the
Commission. In the exercise of its comprehensive powers over revenue,
finance and currency, Congress may make Treasury notes legal tender in
payment of debts previously contracted[171] and may invalidate
provisions in private contracts calling for payment in gold coin.[172]
An award of additional compensation under the Longshoremen's and Harbor
Workers' Compensation Act,[173] made pursuant to a private act of
Congress passed after expiration of the period for review of the
original award, directing the Commission to review the case and issue a
new order, was held valid against the employer and insurer.[174] The
application of a statute providing for tobacco marketing quotas, to a
crop planted prior t