| Heckler v. Chaney | |
|---|---|
 | |
| Argued December 3, 1984 Decided March 20, 1985 | |
| Full case name | Margaret M. Heckler, Secretary of Health and Human Services v. Larry Leon Chaney, et al. |
| Citations | 470 U.S. 821 (more) 105 S. Ct. 1649; 84 L. Ed. 2d 714; 1985 U.S. LEXIS 78; 53 U.S.L.W. 4385; 15 ELR 20335 |
| Case history | |
| Prior | Certiorari to the United States Court of Appeals for the District of Columbia Circuit |
| Holding | |
| The FDA's decision not to take the enforcement actions requested by respondents was not subject to review under the Administrative Procedure Act. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rehnquist, joined by Burger, Brennan, White, Blackmun, Powell, Stevens, O'Connor |
| Concurrence | Brennan |
| Concurrence | Marshall (in judgment) |
| Laws applied | |
| Administrative Procedure Act | |
Heckler v. Chaney, 470 U.S. 821 (1985), is a decision of the Supreme Court of the United States which ruled that a federal agency's decision to not take an enforcement action is presumptively unreviewable by the courts under section 701(a)(2) of the Administrative Procedure Act (APA). The case arose out of a petition to the Food and Drug Administration (FDA) by a group of death row inmates, who sought to have the agency act against states' plans to execute them by lethal injection. The FDA declined to interfere, a decision the inmates appealed unsuccessfully to the District Court for the District of Columbia. On further review, the D.C. Circuit Court of Appeals held that the FDA's action was reviewable and that its denial was "arbitrary and capricious". The Supreme Court unanimously reversed the appeals court and declared in an 8–1 decision that agency nonenforcement decisions were presumptively unreviewable.
The case hinged on various interpretations of sections 706 and 701(a) of the APA; the former allows for general reviewability of agency actions and empowers courts to set them aside when they are found to be "arbitrary, capricious, [or] an abuse of discretion", while the latter lists two exceptions, preventing review where it is expressly exempted by statute or "committed to agency discretion by law". The Supreme Court had previously attempted to resolve the tensions within these statutory provisions. In Abbott Laboratories v. Gardner (1967), the court ruled that agency actions are presumptively reviewable under section 706. In Citizens to Preserve Overton Park v. Volpe (1971), the court ruled that the section 701(a)(2) exemption for actions "committed to agency discretion" applies only where "statutes are drawn in such broad terms that in a given case there is no law to apply" under the relevant standards of review, a holding which provoked some criticism from lower courts and the wider legal community.
In Chaney, the Court of Appeals used nonstatutory considerations to rule the agency action to be reviewable, as it had previously done in cases where it applied Overton Park. The Supreme Court overturned the appeals court's decision and upheld Overton Park's emphasis on statutory considerations, but the presumption of unreviewability it created in this case was largely based on nonstatutory considerations as well. It reasoned that, in general, agency nonenforcement decisions did not easily lend themselves to manageable standards of judicial review, likening those decisions to those that a prosecutor might make. It highlighted, however, that the presumption of unreviewability can be rebutted where the plaintiffs provide "law to apply" that limits the discretion of the agency.
Justice William J. Brennan Jr. concurred and emphasized that the court was not closing off all avenues of review for nonenforcement decisions. Justice Thurgood Marshall concurred in the judgment only, criticizing the majority's decision to create a presumption of unreviewability and instead arguing that the FDA's decision should have been held to be reviewable and upheld on the merits. Lower courts largely accepted the ruling, albeit with varying interpretations of scope, while the wider legal community criticized the majority's rationale for a presumption of unreviewability while agreeing with the result immediately concerning the inmates.
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