Heckler v Chaney (limits on enforcement review)
Heckler v. Chaney (1985)
Facts:
The case arose when death row inmates challenged the FDA’s refusal to take enforcement action against certain drugs used in lethal injections.
The inmates argued that the FDA should have acted against the drugs as unlawful under the Federal Food, Drug, and Cosmetic Act.
The issue was whether the FDA’s decision not to enforce the law against certain drugs was subject to judicial review.
Holding:
The U.S. Supreme Court ruled agency decisions to refuse enforcement are presumptively unreviewable.
The Court reasoned that agencies have broad discretion in deciding whether or not to enforce statutes.
This discretion is based on:
Practical concerns (limited resources),
Policy considerations,
Separation of powers (executive branch discretion).
Legal Principle:
Non-enforcement decisions are presumptively immune from judicial review, unless there is a clear statutory mandate requiring enforcement or a constitutional violation.
Distinguishes enforcement discretion from rulemaking or adjudicatory decisions, which are generally reviewable.
Significance of Heckler v. Chaney
Established a strong presumption against judicial review of agency refusal to act.
Recognizes the executive branch’s discretion in allocating enforcement resources and priorities.
Prevents courts from second-guessing policy decisions best left to agencies.
Related Case Laws on Limits of Enforcement Review
1. Citizens to Preserve Overton Park v. Volpe (1971)
Facts: Challenged the Secretary of Transportation’s approval of a highway construction project through a public park.
Relation: Though this case involved review of a substantive agency decision, it distinguished discretionary decisions and emphasized courts can review certain agency actions if they are “final” and legally constrained.
Significance: Courts can review agency actions if there is a legal mandate, unlike in Heckler where refusal to act was discretionary.
2. Lincoln v. Vigil (1992)
Facts: Challenged the Health Care Financing Administration’s refusal to grant a waiver of certain Medicare requirements.
Holding: Court held the agency’s refusal was a final agency action and subject to review.
Contrast with Heckler: Unlike non-enforcement decisions, denials or refusals to grant benefits or waivers are reviewable because they affect legal rights.
3. Duncan v. U.S. Department of Agriculture (1986)
Facts: Farmers challenged USDA’s refusal to enforce regulations about milk pricing.
Holding: Court applied Heckler v. Chaney and declined review of USDA’s refusal to enforce, emphasizing agency discretion.
Significance: Reinforces the presumption of non-reviewability of enforcement refusals.
4. Town of Castle Rock v. Gonzales (2005)
Facts: Town police refused to enforce a restraining order, and the petitioner sued.
Relation: Though not an administrative law case, it underscores discretionary enforcement immunity in government agencies.
Holding: No constitutional right to enforcement, courts hesitant to compel discretionary enforcement.
5. Sierra Club v. U.S. Environmental Protection Agency (2007)
Facts: Environmental groups challenged EPA’s failure to enforce pollution limits.
Holding: Court distinguished between non-enforcement discretion and mandatory enforcement duties.
Significance: If statute clearly requires enforcement, agency refusal can be reviewed; otherwise, Heckler presumption applies.
Summary Table
| Case | Issue | Holding on Enforcement Review |
|---|---|---|
| Heckler v. Chaney (1985) | FDA refusal to enforce drug laws | Enforcement refusal presumptively unreviewable |
| Citizens to Preserve Overton Park (1971) | Reviewability of agency approval decisions | Courts review final agency action if statutory mandates apply |
| Lincoln v. Vigil (1992) | Denial of waiver under Medicare | Denials of benefits/waivers are reviewable |
| Duncan v. USDA (1986) | USDA refusal to enforce milk pricing | Enforcement refusal non-reviewable under Heckler |
| Town of Castle Rock v. Gonzales (2005) | Police refusal to enforce restraining order | Discretionary enforcement generally immune |
| Sierra Club v. EPA (2007) | EPA refusal to enforce pollution rules | Review possible if statute mandates enforcement |
Conclusion
Heckler v. Chaney set a foundational rule in administrative law: agency decisions not to enforce are generally immune from judicial review, preserving executive discretion and separation of powers. This presumption is strong but not absolute; when a statute mandates enforcement or constitutional rights are at stake, courts may intervene.
Other cases reinforce this framework by clarifying when enforcement decisions are reviewable (denials of benefits, waivers) versus when they remain within agency discretion (non-enforcement).
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