Supreme Court of the United States
Heckler v. Chaney
March 20, 1985470 U.S. 821
Summary
The Court held that an agency's refusal to institute investigative or enforcement proceedings is presumptively committed to agency discretion and therefore unreviewable under the Administrative Procedure Act. That presumption may be overcome when the governing statute supplies meaningful standards limiting enforcement discretion, but the Food, Drug, and Cosmetic Act did not do so here. The Court therefore reversed the Court of Appeals.
Holding
- Reviewability of an agency's refusal to institute enforcement proceedings. An agency's decision not to institute investigative or enforcement proceedings is presumptively unreviewable under the Administrative Procedure Act because it is generally committed to agency discretion by law.
- Whether the Food, Drug, and Cosmetic Act supplies standards permitting review of the FDA's refusal to enforce. The Food, Drug, and Cosmetic Act does not overcome the presumption of unreviewability because its enforcement provisions do not meaningfully limit the Secretary's discretion to decide whether and when to investigate, seek injunctions, pursue seizures, or recommend criminal prosecution.
Docket 83-1878
Cited authorities
- 21 U.S.C. §§ 352
- 5 U.S.C. §§ 701-706
- 5 U.S.C. §§ 701-706
- 21 U.S.C. § 355
- 5 U.S.C. §§ 701-706
- CA10
- 5 U.S.C. § 501
- 52 Stat. 1040
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