The federal administrative system has exhibited a steady increase in integration. In the earlier years subordinate administrative officials were accustomed to act in individual cases without feeling themselves bound to consult the judgment of those higher in office, nor did they hold themselves necessarily bound by directions from such source. The principle followed by them was that they, as well as those in higher position, derived their authority by direct grant from Congress and were subject to control and direction only by that body or by the courts. The necessities of efficient government have, however, compelled Congress to place express powers of control over their subordinates in the hands of administrative chiefs, and have persuaded the courts to recognize, whenever possible, the existence of these supervisory powers even where express statutory provision has not been made for their exercise. Professor Goodnow, commenting on this development, says: "At the present time the collectors of the customs would hardly think of attempting to apply a law in a doubtful case without first receiving instructions from the Secretary of the Treasury (Rev. St., § 2652) and the law makes an appeal from the collector of internal revenue to the Treasury Department necessary before the aggrieved party has any standing in court. Rev. St., § 3226. This was the case also in the customs administration until the passage of the customs administrative law of 1890 which took away the administrative remedy of appeal to the Secretary of the Treasury and provided an appeal to the general appraisers. The same thing is true in many cases in the Department of Interior (Rev. St., § 2273). Finally it has been held that the head of a department may change the erroneous decision of a subordinate (U. S. v. Cobb, 11 Fed. Rep. 76) and that any person aggrieved by the refusal of a subordinate to obey the order of the head of a department may obtain from the proper court a mandamus to force the subordinate to obey such order. Miller v. Black, 128 U. S. 50." 18