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Massachusetts Fair Share v. Law Enforcement Assistance Administration

Court of Appeals for the D.C. Circuit
244 U.S. App. D.C. 388, 758 F.2d 708 (1985)
ELI5:

Rule of Law:

A federal agency must adhere to its own self-adopted procedures, and when two agencies establish a joint program requiring joint action, one agency cannot unilaterally reverse a decision that was made jointly.


Facts:

  • The Law Enforcement Assistance Administration (LEAA) and the Agency for Voluntary Service (ACTION) entered into a memorandum of agreement to create and jointly manage the Urban Crime Prevention Program.
  • The agreement and all related program documents stipulated that grant applications would be jointly developed, evaluated, and selected by both agencies.
  • Massachusetts Fair Share submitted an application for its Boston Arson Prevention Project under this program.
  • After a joint review process involving staff from both agencies, the Administrator of LEAA and the Director of ACTION jointly selected Massachusetts Fair Share as a 'finalist' for funding, contingent upon resolving 'minor programmatic and financial issues.'
  • Following this joint conditional approval, LEAA officials, without the participation of ACTION, conducted a further investigation of the proposal.
  • The Director of ACTION requested the LEAA Administrator to execute the final grant documents, but the Administrator refused.
  • The LEAA Administrator sent a letter to Massachusetts Fair Share denying its application, a letter which the ACTION Director refused to sign.

Procedural Posture:

  • The LEAA Administrator sent a letter to Massachusetts Fair Share denying its grant application.
  • Massachusetts Fair Share filed an administrative protest of the denial.
  • An administrative hearing was held, and the hearing officer ruled that LEAA's unilateral rejection was void because it violated the joint-action requirement.
  • The hearing officer's determination was reviewed by a Department of Justice administrator.
  • The Department of Justice administrator reversed the hearing officer's decision, concluding that the grant rejection was justified.
  • Having exhausted its administrative remedies, Massachusetts Fair Share petitioned the U.S. Court of Appeals for the D.C. Circuit for review of the final agency decision.

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Issue:

Does an administrative agency violate its own procedures when it unilaterally denies a grant application after that application was jointly and conditionally approved with a partner agency, under a program explicitly designed for joint decision-making?


Opinions:

Majority - Spottswood W. Robinson, III

Yes. An agency violates its own procedures when it unilaterally rejects an application that was jointly and conditionally approved under a program requiring joint action. It is a long-settled principle of administrative law that an agency must adhere to its self-adopted rules. The court found that all basic documents establishing the Urban Crime Prevention Program—including the memorandum of agreement, the Federal Register notice, and the guideline manual—unambiguously contemplated joint decision-making by LEAA and ACTION at every critical stage. The joint selection of petitioner as a finalist constituted a formal decision, and the contingency clause for resolving 'minor issues' did not grant either agency the authority to unilaterally abrogate that decision. The power to revoke the conditional grant, just like the power to award it, was subject to the requirement of joint agency action, and LEAA had no authority to act alone.



Analysis:

This decision reinforces the Accardi doctrine, which holds that government agencies are bound by their own regulations and procedures. The court's ruling extends this principle to inter-agency agreements and internally adopted guidelines, confirming they can create binding obligations on the agencies and procedural rights for third parties. This precedent strengthens the position of applicants in cooperative government programs by protecting them from arbitrary, unilateral agency actions that deviate from a mutually agreed-upon process. It ensures predictability and fairness by holding agencies accountable to the specific frameworks they create for joint ventures.

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