Constitutional basis of administrative law in the USA
Constitutional Basis of Administrative Law in the USA
Administrative law governs the activities of administrative agencies of government. In the U.S., the foundation of administrative law lies primarily in the Constitution, specifically in the way it structures the powers and limitations of the three branches of government:
Separation of Powers: The U.S. Constitution divides government power into three branches—legislative (Congress), executive (President and agencies), and judicial (courts). Administrative agencies exercise a form of delegated authority from Congress, primarily under the executive branch, but sometimes with quasi-judicial powers.
Delegation Doctrine: Article I of the Constitution vests all legislative powers in Congress. However, Congress often delegates authority to administrative agencies to make rules (regulations) and enforce them. The constitutionality of this delegation rests on Congress providing an "intelligible principle" to guide the agency.
Due Process Clause (5th and 14th Amendments): Protects individuals from arbitrary government action, requiring fair procedures (e.g., hearings) when agencies affect rights.
Judicial Review: Under Article III, courts review administrative agency actions to ensure they do not exceed statutory authority, violate the Constitution, or abuse discretion.
Key Cases in Administrative Law and Their Constitutional Significance
1. Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. (1984)
Issue: How should courts review an administrative agency’s interpretation of a statute that it administers?
Facts: The EPA interpreted the Clean Air Act in a way that was challenged by NRDC, claiming the EPA’s interpretation was unreasonable.
Holding: The Supreme Court established the famous Chevron deference doctrine. When a statute is ambiguous and an agency's interpretation is reasonable, courts should defer to the agency’s interpretation.
Constitutional significance: This case clarified the extent of judicial deference to agencies, reinforcing the idea that Congress can delegate regulatory power, and agencies have expertise in interpreting complex statutes.
2. INS v. Chadha (1983)
Issue: Whether the legislative veto (Congress overturning an executive decision without passing a law) violates the Constitution.
Facts: The Immigration and Nationality Act allowed one house of Congress to veto decisions made by the Attorney General to suspend deportation.
Holding: The Supreme Court ruled the legislative veto unconstitutional because it bypassed the bicameralism and presentment requirements of Article I.
Constitutional significance: The decision reinforced the separation of powers, restricting Congress's ability to control administrative decisions without going through proper legislative procedures.
3. American Trucking Ass’ns v. Interstate Commerce Commission (1952)
Issue: The scope of judicial review over agency factual findings.
Holding: The Court stated courts must defer to an agency’s findings of fact if supported by substantial evidence in the record.
Constitutional significance: This case strengthened the idea that agencies are the primary fact-finders due to their expertise, with courts providing oversight without substituting their judgment.
4. Goldberg v. Kelly (1970)
Issue: Does the Due Process Clause require a hearing before welfare benefits are terminated?
Facts: New York stopped welfare payments without a prior hearing.
Holding: The Supreme Court held that due process requires a pre-termination evidentiary hearing because welfare benefits are a form of property.
Constitutional significance: This case cemented procedural due process in administrative decisions affecting individuals’ rights, requiring fair procedures before government action deprives a person of life, liberty, or property.
5. Morgan v. United States (1936)
Issue: Whether agencies must provide hearings before making adjudicative decisions.
Holding: The Court held that agencies should follow formal hearing procedures before making decisions that affect individual rights.
Constitutional significance: It established procedural safeguards within administrative adjudications, reinforcing fairness in administrative processes under the Constitution.
6. Buckley v. Valeo (1976)
Issue: The constitutionality of the appointment of administrative officers.
Facts: The Federal Election Commission (FEC) included members who were not appointed following the Appointments Clause.
Holding: The Court struck down certain appointments that violated the Appointments Clause (Article II), reinforcing the constitutional requirement for appointments of officers.
Constitutional significance: This decision confirmed that administrative officers exercising significant authority must be appointed consistent with the Constitution’s separation of powers.
7. Citizens to Preserve Overton Park v. Volpe (1971)
Issue: Standards of judicial review for administrative decisions.
Holding: The Court held that courts must review administrative decisions to ensure they are not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law.
Constitutional significance: It established the arbitrary and capricious standard under the Administrative Procedure Act (APA), ensuring judicial oversight while respecting agency expertise.
Summary
The Constitution provides the framework for administrative agencies by allowing delegation of legislative powers but requires an "intelligible principle" to guide agencies.
Agencies operate under separation of powers principles and must respect procedural due process.
The judiciary reviews agency actions under standards shaped by cases like Chevron, ensuring agencies do not exceed their authority.
Cases like Chadha and Buckley ensure Congress and the President do not bypass constitutional requirements in controlling agencies.
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