Democrats lost six Senate

nservative Democrats in Congress (mostly from the South), Roosevelt involved himself in the 1938 Democratic primaries, actively campaigning for challengers who were more supportive of New Deal reform. His targets denounced Roosevelt for trying to take over the Democratic party and used the argument that they were independent to win reelection. Roosevelt failed badly, managing to defeat only one target, a conservative Democrat from New York City.[81]
In the November 1938 election, Democrats lost six Senate s

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obstacle to Roosevelt's programs during his second term, overturning many of his programs. In particular in 1935 the Court unanimously ruled that the National Recovery Act (NRA) was an unconstitutional delegation of legislative power to the president. Roosevelt stunned Congress in early 1937 by proposing a law allowing him to appoint up to six new justices, a "persistent infusion of new blood."[78] This "court packing" plan ran into intense political opposition from his own party, led by Vice President Garner, since it seemed to upset the separation of powers and give the President control over the Court. Roosevelt's proposals were defeated. The Court also drew back from confrontation with the administration by finding the Labor Relations and Social Security Acts to be constitutional. Deaths and retirements on the Supreme Court soon allowed Roosevelt to make his own appointments to the

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