Concurrence Douglas | Date decided 1975 | |
Full case name Train v. City of New York Citations 420 U.S. 35 (more)
95 S. Ct. 839; 43 L. Ed. 2d 1 Majority White, joined by Burger, Brennan, Stewart, Marshall, Blackmun, Powell, and Rehnquist People also search for Collector v. Day, Kidd v. Pearson | ||
Train v. City of New York, 420 U.S. 35 (1975), was a case in the Supreme Court of the United States whose implications mean "[t]he president cannot frustrate the will of Congress by killing a program through impoundment."
In this case, President Richard Nixon was of the view that the administration was not obligated to disburse all funds allocated by Congress to states seeking federal monetary assistance under the Federal Water Pollution Control Act Amendments of 1972 and ordered the impoundment of substantial amounts of environmental protection funds for a program he vetoed, and which had been overridden by Congress. Russell E. Train, the administrator of the EPA at the time, complied with the order. Several prospective recipients of the funds (which were intended to subsidize construction of municipal sewers and water treatment works), including the city of New York and several other municipalities, promptly sued, seeking judgment that the administrator was obligated to disburse full amounts authorized and an order directing him to make those allotments.
The Court ruled that the president could not order the impoundment of substantial amounts of environmental protection funds for a program in these circumstances. The president cannot frustrate the will of Congress by killing a program through impoundment.
The case arose from facts which pre-date the Congressional Budget and Impoundment Control Act of 1974, though the case was argued after the passing of the 1974 Act. The case showed that the presidential power of impoundment, even without the 1974 Act, was not unlimited and that the president is required to carry out the full objectives or scope of programs for which budget authority is provided by the United States Congress. In this case, the president could not order the impoundment of substantial amounts of environmental protection funds for a program he vetoed, and which had been overridden by Congress. This finding closed a potential loophole in the Act.