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Lincoln v. Vigil

United States Supreme Court
508 U.S. 182 (1993)
ELI5:

Rule of Law:

An agency's decision to allocate funds from a lump-sum appropriation is an action "committed to agency discretion by law" under § 701(a)(2) of the Administrative Procedure Act (APA) and is therefore not subject to judicial review. Furthermore, such a decision is considered a "general statement of policy" under § 553(b)(A) and is exempt from the APA's notice-and-comment rulemaking requirements.


Facts:

  • From 1978 to 1985, the Indian Health Service (IHS), a federal agency, provided direct clinical services to handicapped Indian children in the Southwest through its Indian Children's Program.
  • The program was internally funded by the IHS using money from its annual lump-sum appropriations from Congress, which were designated for the general purpose of Indian health care.
  • Congress never passed a statute specifically authorizing or appropriating funds for the Indian Children's Program, though the IHS repeatedly informed Congress of the program's operations during budget hearings.
  • In August 1985, the IHS decided to discontinue the program's direct clinical services in the Southwest.
  • The IHS planned to reallocate the program's resources and reassign its staff to serve as consultants for a nationwide mental health initiative for Indian children, rather than providing direct regional services.
  • The IHS announced this decision via an internal memorandum to its service offices and program referral sources.

Procedural Posture:

  • Respondents, handicapped Indian children eligible for the program, sued the Director of the Indian Health Service (the petitioners) in the U.S. District Court for the District of New Mexico, seeking to have the program reinstated.
  • The District Court granted summary judgment for the respondents, holding that the decision was reviewable and that the agency had improperly failed to follow APA notice-and-comment rulemaking procedures.
  • The District Court ordered the IHS to reinstate the Indian Children's Program.
  • Petitioners (IHS) appealed the District Court's decision to the U.S. Court of Appeals for the Tenth Circuit.
  • The Court of Appeals affirmed the District Court's judgment, agreeing that the decision was reviewable and required notice-and-comment.
  • The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.

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Issue:

Is a federal agency's decision to terminate a discretionary program funded through a lump-sum congressional appropriation subject to judicial review and the notice-and-comment requirements of the Administrative Procedure Act?


Opinions:

Majority - Justice Souter

No, a federal agency's decision to terminate a discretionary program funded through a lump-sum congressional appropriation is not subject to judicial review or the notice-and-comment requirements of the Administrative Procedure Act. First, the decision is not judicially reviewable because it is an action "committed to agency discretion by law" under APA § 701(a)(2). The very purpose of a lump-sum appropriation is to give an agency flexibility to allocate resources to meet its statutory mandate as it sees fit. Without a specific statutory directive, there is no meaningful standard against which a court can judge the agency's exercise of discretion. Mentions of the program in legislative history do not create a legally binding obligation on the agency. Second, the decision did not require notice-and-comment rulemaking under APA § 553. Even if the termination is a "rule," it falls under the exemption for "general statements of policy" because it is an announcement of how the agency plans to exercise a discretionary power. It did not alter eligibility criteria for services but merely affected the availability of one specific program in a particular geographic area.



Analysis:

This decision significantly reinforces judicial deference to agency resource allocation decisions, especially when Congress provides funding through lump-sum appropriations. It clarifies that legislative history, such as committee reports acknowledging a program, does not create judicially enforceable mandates unless those directives are codified in the statutory text itself. The ruling solidifies the high bar for overcoming the APA's "committed to agency discretion" exception, thereby insulating a broad category of internal agency budgetary and programmatic choices from judicial oversight. It also narrowly construes what constitutes formal rulemaking, allowing agencies to make significant policy shifts through less formal announcements without public input.

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