WHITMAN V. AMERICAN TRUCKING ASSOCIATIONS, INC. 531 U.S. 457 (2001) CASE BRIEF

WHITMAN V. AMERICAN TRUCKING ASSOCIATIONS, INC.
531 U.S. 457 (2001)
NATURE OF THE CASE: This was a dispute over whether 109(b)(1) of the Clean Air Act delegates legislative power to the EPA and if the EPA can consider the costs of implementation for NAAQS.
FACTS: Section 109(a) of the Clean Air Act requires the Administrator of the EPA to promulgate National Ambient Air Quality Standards (NAAQS) for each air pollutant for which 'air quality criteria' have been issued under 108, 42 U. S. C. 7408. The Administrator must review the standard 'at five-year intervals' and make 'such revisions ... as may be appropriate.' American Trucking Associations, Inc., et al (P)-challenged the new standards in the Court of Appeals for the District of Columbia Circuit, pursuant to 42 U. S. C. 7607(b)(1). The District Court agreed that 109(b)(1) delegated legislative power to the Administrator in contravention of the United States Constitution, Art. I, 1, because it found that the EPA had interpreted the statute to provide no 'intelligible principle' to guide the agency's exercise of authority. The court thought that the EPA could perhaps avoid the unconstitutional delegation by adopting a restrictive construction of 109(b)(1), so instead of declaring the section unconstitutional the court remanded the NAAQS to the agency. Eventually, the Supreme Court granted certiorari.

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