Foundations of U S Administrative Law
Foundations of U.S. Administrative Law
What is Administrative Law?
Administrative law governs the activities of administrative agencies of the government. These agencies have been created by Congress or state legislatures to enforce specific statutes and carry out specialized regulatory or enforcement functions.
Key features:
Rulemaking (legislative function)
Adjudication (judicial function)
Enforcement and investigation (executive function)
Core Principles of U.S. Administrative Law
Delegation of Authority: Congress delegates legislative power to administrative agencies to fill in the details.
Rulemaking: Agencies can issue regulations that have the force of law.
Adjudication: Agencies can conduct hearings and make decisions affecting rights.
Judicial Review: Courts review agency actions to ensure they comply with law and constitutional principles.
Due Process: Individuals affected by agency decisions are entitled to fair procedures.
Landmark Cases Explaining Foundations of U.S. Administrative Law
1. Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)
Facts: The Environmental Protection Agency (EPA) interpreted the Clean Air Act to allow states to adopt a flexible permit program. The NRDC challenged this interpretation.
Issue: When a statute is ambiguous, should courts defer to an agency’s interpretation?
Holding: The Supreme Court established the Chevron deference doctrine.
Reasoning: If Congress has not directly spoken to an issue, courts must defer to the agency’s reasonable interpretation of the statute it administers.
Significance: This case set the standard for judicial deference to agency interpretations, balancing agency expertise and congressional intent.
2. Auer v. Robbins, 519 U.S. 452 (1997)
Facts: The issue was whether courts should defer to an agency’s interpretation of its own ambiguous regulations.
Issue: Should courts defer to an agency’s interpretation of its own regulations?
Holding: The Court ruled in favor of deference to the agency’s interpretation of its own rules unless it is plainly erroneous.
Significance: Known as Auer deference, this case extended Chevron deference to an agency’s interpretation of its own rules, underscoring agency expertise.
3. Goldberg v. Kelly, 397 U.S. 254 (1970)
Facts: Kelly’s welfare benefits were terminated without a pre-termination hearing.
Issue: Does due process require a hearing before welfare benefits are terminated?
Holding: Yes. The Court held that due process requires an evidentiary hearing before termination of benefits.
Reasoning: Welfare benefits are a form of property; thus, due process protections apply.
Significance: Established that administrative agencies must provide due process protections, including notice and hearing, before depriving individuals of significant interests.
4. Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402 (1971)
Facts: Citizens challenged the Secretary of Transportation’s decision to approve highway construction through a park.
Issue: What is the scope of judicial review of agency decisions under the Administrative Procedure Act (APA)?
Holding: Courts must conduct a thorough, probing, and in-depth review of the agency’s decision, and can set it aside if arbitrary, capricious, or unsupported by evidence.
Significance: This case clarified the standards for judicial review of agency decisions and emphasized that courts should not defer blindly but ensure reasoned decision-making.
5. INS v. Chadha, 462 U.S. 919 (1983)
Facts: The Immigration and Nationality Act allowed either House of Congress to veto the Attorney General’s suspension of deportation.
Issue: Is the legislative veto constitutional?
Holding: The Supreme Court held that the legislative veto violated the separation of powers because Congress cannot exercise legislative power without bicameralism and presentment.
Significance: Reinforced constitutional limits on agency and legislative powers and clarified the boundaries of delegation.
6. Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29 (1983)
Facts: The Department of Transportation rescinded a passive restraint safety requirement without proper explanation.
Issue: Was the rescission arbitrary and capricious under the APA?
Holding: Yes. The Court held that agency actions must be reasonable and explained.
Significance: This case reinforced the arbitrary and capricious standard of judicial review, requiring agencies to provide rational explanations for their actions.
7. Panama Refining Co. v. Ryan, 293 U.S. 388 (1935)
Facts: The National Industrial Recovery Act delegated broad power to the President to prohibit interstate shipment of petroleum.
Issue: Was the delegation of legislative power too broad (an unconstitutional delegation)?
Holding: The Court ruled the delegation was unconstitutional for lack of clear standards.
Significance: Early example of the nondelegation doctrine, establishing limits on Congress’s power to delegate legislative authority to agencies.
Summary Table of Key Cases and Their Contributions
| Case | Key Principle | Contribution to Administrative Law |
|---|---|---|
| Chevron U.S.A. v. NRDC (1984) | Judicial deference to agency | Established Chevron deference to agency statutory interpretations |
| Auer v. Robbins (1997) | Agency interpretation of own rules | Extended deference to agency interpretations of regulations |
| Goldberg v. Kelly (1970) | Due process in administrative actions | Requires hearing before deprivation of benefits |
| Citizens to Preserve Overton Park (1971) | Judicial review of agency decisions | Defined arbitrary and capricious standard under APA |
| INS v. Chadha (1983) | Separation of powers | Invalidated legislative veto on constitutional grounds |
| Motor Vehicle Mfrs. Assn. v. State Farm (1983) | Arbitrary and capricious review | Agencies must provide reasoned explanations |
| Panama Refining Co. v. Ryan (1935) | Nondelegation doctrine | Limits on Congress’s delegation of legislative power |
Conclusion
The foundations of U.S. administrative law rest on the balance of powers, ensuring agencies can efficiently regulate but must do so within constitutional and statutory limits. Judicial review protects individuals from arbitrary agency action, and doctrines like Chevron and Auer deference recognize agency expertise while maintaining accountability.
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