SmartBrief
Confirm favorite deletion?
Administrative Law Keyed to Breyer
Whitman v. American Trucking Associations, Inc.
Citation:
531 U.S. 457 (2001)Facts
In July 1997, the EPA, under the authority of Section 109 of the Clean Air Act, revised the National Ambient Air Quality Standards for particulate matter and ozone. The American Trucking Associations, along with other industry groups and several states, challenged these revised standards in the D.C. Circuit Court of Appeals. The challengers argued that Section 109 of the Clean Air Act constituted an unconstitutional delegation of legislative power because it provided no “intelligible principle” to guide the EPA’s exercise of discretion in setting air quality standards. They also contended that the EPA should consider economic costs of implementation when establishing NAAQS. The D.C. Circuit agreed with the nondelegation argument but rejected the cost consideration argument. The court remanded to the EPA to adopt a limiting construction of the statute rather than invalidating the provision. The EPA appealed, arguing that Section 109 did provide an intelligible principle and that the court lacked jurisdiction to review the EPA’s implementation policy for the revised ozone standard.
#Issue:
Does Section 109(b)(1) of the Clean Air Act permit the EPA to consider the costs of implementation in setting national ambient air quality standards, and does it delegate legislative power to the EPA in violation of Article I, §1 of the Constitution?
#Holding:
No, the Clean Air Act does not permit the EPA to consider implementation costs when setting NAAQS. Additionally, Section 109(b)(1) does not unconstitutionally delegate legislative power to the EPA, as it provides a sufficiently intelligible principle to guide the agency’s discretion.
#Concurring Opinions:
Only StudyBuddy Pro offers the complete Case Brief Anatomy*
Access the most important case brief elements for optimal case understanding.
*Case Brief Anatomy includes: Brief Prologue, Complete Case Brief, Brief Epilogue
- The Brief Prologue provides necessary case brief introductory information and includes:
Topic:
Identifies the topic of law and where this case fits within your course outline.Parties:
Identifies the cast of characters involved in the case.Procedural Posture & History:
Shares the case history with how lower courts have ruled on the matter.Case Key Terms, Acts, Doctrines, etc.:
A case specific Legal Term Dictionary.Case Doctrines, Acts, Statutes, Amendments and Treatises:
Identifies and Defines Legal Authority used in this case.
- The Case Brief is the complete case summarized and authored in the traditional Law School I.R.A.C. format. The Pro case brief includes:
Brief Facts:
A Synopsis of the Facts of the case.Rule of Law:
Identifies the Legal Principle the Court used in deciding the case.Facts:
What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case.Issue(s):
Lists the Questions of Law that are raised by the Facts of the case.Holding:
Shares the Court's answer to the legal questions raised in the issue.Concurring / Dissenting Opinions:
Includes valuable concurring or dissenting opinions and their key points.Reasoning and Analysis:
Identifies the chain of argument(s) which led the judges to rule as they did.
- The Brief Prologue closes the case brief with important forward-looking discussion and includes:
Policy:
Identifies the Policy if any that has been established by the case.Court Direction:
Shares where the Court went from here for this case.