Lincoln v. Vigil

Summary

Justice Souter delivered the unanimous opinion holding that the Indian Health Service’s decision to discontinue a regional program for handicapped Indian children and reallocate its resources nationwide was committed to agency discretion and therefore not subject to substantive review under the Administrative Procedure Act. Congress had provided unrestricted lump-sum appropriations, and neither legislative history nor the federal trust relationship with Indians required continuation of the regional program. The Court also held that the decision did not require notice-and-comment rulemaking because an announcement discontinuing a discretionary allocation of unrestricted funds qualifies as a general statement of policy. The Court reversed and remanded, leaving constitutional claims for consideration on remand and expressing no view on publication requirements or the propriety of the District Court’s relief. There were no separate opinions.