Far East Conference V. United States

In Far East Conference v. United States, 342 U.S. 570, 574-75 (1952), the United States Supreme Court identified primary jurisdiction doctrine as "a principle, now firmly established, that in cases raising issues of fact not within the conventional expertise of judges or cases requiring the exercise of administrative discretion, agencies created by Congress for regulating the subject matter should not be passed over."

The primary jurisdiction doctrine is a discretionary tool that allows a court to refer certain complex factual questions to an administrative body for an initial determination.