Train v. City of New York
1975 U.S. LEXIS 104, 95 S. Ct. 839, 420 U.S. 35 (1975)
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Rule of Law:
The Federal Water Pollution Control Act Amendments of 1972 require the Administrator of the Environmental Protection Agency to allot to the States the full amounts authorized to be appropriated by Congress for municipal sewage treatment works, as the Act does not grant the Executive the discretion to withhold or reduce these allotments.
Facts:
- Congress passed the Federal Water Pollution Control Act Amendments of 1972 (1972 Act) to create a comprehensive program for controlling and abating water pollution.
- Section 207 of the 1972 Act authorized the appropriation of "not to exceed" $5 billion for fiscal year 1973, $6 billion for fiscal year 1974, and $7 billion for fiscal year 1975 for municipal sewers and sewage treatment works.
- The 1972 Act was passed by Congress on October 4, 1972, but President Nixon vetoed it on October 17, 1972.
- Congress promptly overrode President Nixon's veto.
- On November 22, 1972, President Nixon directed William D. Ruckelshaus, the Administrator of the Environmental Protection Agency, not to allot the maximum amounts, but instead to allot "no more than $2 billion" for fiscal year 1973 and "no more than $3 billion" for fiscal year 1974.
- On December 8, 1972, Administrator Ruckelshaus announced by regulation that he was allotting only $2 billion and $3 billion for fiscal years 1973 and 1974, respectively.
- The city of New York and other similarly situated municipalities were impacted by these reduced allotments.
Procedural Posture:
- The city of New York and other municipalities in New York State filed a complaint against the Administrator of the Environmental Protection Agency in federal District Court, seeking a declaration that the Administrator was obligated to allot the full authorized amounts and an order to make those allotments.
- The District Court denied the Administrator’s motion to dismiss and granted the cities’ motion for summary judgment.
- The Court of Appeals for the District of Columbia Circuit affirmed the District Court's decision, holding that "the Act requires the Administrator to allot the full sums authorized to be appropriated in § 207."
- The U.S. Supreme Court granted certiorari due to differing views on the proper construction of the Act between the federal courts in the District of Columbia (in this case) and those of the Fourth Circuit (in Train v. Campaign Clean Water).
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Issue:
Does the Federal Water Pollution Control Act Amendments of 1972 permit the Administrator of the Environmental Protection Agency to allot to the States less than the entire amounts authorized to be appropriated by Congress for federal financial assistance for municipal sewage treatment works?
Opinions:
Majority - White
No, the Federal Water Pollution Control Act Amendments of 1972 do not permit the Administrator to allot less than the full amounts authorized by Congress. The Court reasoned that Section 205(a) explicitly states that "sums authorized to be appropriated pursuant to [§ 207]... shall be allotted by the Administrator." While Section 207 uses the phrase "not to exceed" specific amounts, this language merely establishes a maximum limit on appropriations, not a discretionary lower limit on the amounts that must be allotted. If the full amount authorized is to be appropriated, then approved municipal projects and grants for those projects can only be made from fully allotted funds. The Court rejected the Administrator's argument that last-minute changes made in the Conference Committee (striking "all" from Section 205 and inserting "not to exceed" in Section 207) were intended to confer broad executive discretion to withhold funds at the allotment stage. The Court found these changes to be "quite inadequate means" to alter the entire complexion and thrust of the Act, which Congress intended as a "firm commitment of substantial sums" to address an urgent water pollution problem. Furthermore, the legislative history indicated that any discretion to control spending was intended to be exercised at the "obligation phase" (when specific grants are made to projects), rather than at the initial "allotment stage" (when funds are distributed to states for future projects).
Analysis:
This case significantly curtails the Executive's power of impoundment, particularly when Congress employs a "contract-authority" funding mechanism designed to ensure a binding commitment of funds. It reinforces the principle that congressional intent, as derived from the plain language and structure of a statute, is paramount, even against an executive branch's asserted need for spending flexibility. The ruling underscores the constitutional separation of powers, affirming Congress's exclusive authority over the appropriation and distribution of federal funds. Future challenges to executive impoundment must demonstrate a clear statutory grant of such discretion, with courts unlikely to infer it from ambiguous language or legislative history.
