Clinton v. City of New York

524 U.S. 417, 118 S.Ct. 2091, 141 L.Ed.2d 393 (1998)

Quick Summary

President Clinton (defendant) used the Line Item Veto Act to cancel provisions in two federal Acts, affecting New York (plaintiff) and Idaho potato farmers (plaintiffs). The plaintiffs argued that the cancellations caused immediate financial harm and challenged their constitutionality.

The main issue was whether this use of the Line Item Veto Act violated the Presentment Clause. The Supreme Court concluded that it did, rendering the Act unconstitutional and invalidating the President’s cancellations.

Facts of the Case

The Line Item Veto Act granted the President power to cancel specific budget items after signing them into law. President Clinton (defendant) exercised this power to cancel a provision in the Balanced Budget Act of 1997, which would have allowed New York (plaintiff) to avoid repaying certain health care funds.

Additionally, he canceled a tax benefit provision in the Taxpayer Relief Act of 1997 that affected a group of Idaho potato farmers (plaintiffs). Both sets of plaintiffs challenged these cancellations, arguing that they resulted in immediate financial injuries. The district court agreed, finding the Act unconstitutional.

Procedural Posture and History

  1. President Clinton canceled specific provisions of two Acts under the Line Item Veto Act.
  2. Plaintiffs challenged the cancellations, claiming financial injury.
  3. The district court found the Line Item Veto Act unconstitutional.
  4. The case was appealed to the United States Supreme Court.

I.R.A.C. Format

Issue

Whether the Line Item Veto Act’s grant of power to the President to cancel specific items in federal legislation violates the Presentment Clause of the U.S. Constitution.

Rule of Law

The constitutional procedures for enacting, amending, or repealing laws require that such actions conform to the Presentment Clause, which mandates that legislation be presented to the President for approval or veto before becoming law.

Reasoning and Analysis

The Supreme Court examined whether the cancellations made by President Clinton under the Line Item Veto Act amounted to an unconstitutional amendment or repeal of portions of statutes.

The Court determined that the President does not possess the authority to unilaterally amend or repeal statutes once they have been duly enacted and signed into law following the constitutional procedure outlined in Article I, Section 7. The Court found that the Line Item Veto Act’s cancellation procedures violated this constitutional requirement.

Conclusion

The Supreme Court held that the Line Item Veto Act was unconstitutional because it allowed the President to unilaterally cancel parts of statutes, bypassing the constitutional legislative process required by the Presentment Clause.

Key Takeaways

  1. The President cannot unilaterally amend or repeal statutes after they have been enacted into law; such actions must follow the procedures set forth in the Constitution.
  2. The Line Item Veto Act was declared unconstitutional because it violated the Presentment Clause by allowing the President to cancel specific items without following constitutional legislative procedures.

Relevant FAQs of this case

Can the executive branch alter laws after they have been passed by the legislative branch and signed into law?

The executive branch cannot alter laws once they have been enacted by the legislative branch and signed into law. The separation of powers doctrine clearly defines the distinct functions of each branch of government, and altering a law is a legislative function.

  • For example: If Congress passes a healthcare bill which is then signed into law by the President, the executive branch cannot later decide to modify or strike down aspects of that law without new legislation being passed by Congress.

What is the constitutional process for amending or repealing federal laws?

The process for amending or repealing federal laws involves passing new legislation through both houses of Congress (the House of Representatives and the Senate), followed by the presentation of the bill to the President for approval or veto, consistent with the Presentment Clause in the Constitution.

  • For example: If there is a desire to amend the Social Security Act, new legislation with the proposed amendments must be introduced, debated, and approved by both chambers of Congress before it is sent to the President for signing into law or veto.

How does a bill become law according to the U.S. Constitution?

A bill becomes law in the United States by first being passed by both the House of Representatives and the Senate. It is then sent to the President, who may sign it into law or veto it. If vetoed, Congress can override the veto with a two-thirds vote in both chambers.

  • For example: Suppose Congress drafts a bill regarding environmental regulations. For it to become law, it must secure a majority vote in both Congressional houses. Once passed, it proceeds to the President, who has the option to enact it into law with a signature or return it with objections; if vetoed, Congress may still make it law with sufficient votes.

References

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