Case Identification
Case name: Immigration and Naturalization Service v. Chadha
Court: Supreme Court of the United States
Jurisdiction: Federal
Year: 1983
Citation: 462 U.S. 919
Claim Presented
The Court considered whether a provision of the Immigration and Nationality Act authorizing one House of Congress to invalidate an executive decision by resolution violated constitutional requirements. Section 244(c)(2) of the Act permitted either House of Congress to pass a resolution overturning the Attorney General’s decision to suspend the deportation of an alien. The question presented was whether this legislative veto mechanism comported with the constitutional structure established by Article I.
Authority Cited
Article I, Section 1 (vesting clause)
Article I, Section 7, Clauses 2 and 3 (Presentment Clause and bicameralism requirements)
Constitutional separation of powers principles
The Court addressed bicameralism and presentment requirements as essential components of the legislative process established by the Constitution.
Court’s Analysis
The legislative veto mechanism allowed one House to overturn an executive deportation suspension by resolution. The Court examined whether this action constituted legislative action requiring bicameral passage and presentment to the President. The Court determined the one-House veto was legislative in character because it had the “purpose and effect of altering the legal rights, duties, and relations of persons” outside the legislative branch. The mechanism did not satisfy constitutional requirements of bicameral approval and presentment. The Court concluded that when Congress acts to alter legal rights and obligations, it must follow the procedures prescribed in Article I, Section 7, which require passage by both Houses and presentment to the President for approval or veto.
Disposition
The statutory provision authorizing the legislative veto was invalidated. The judgment was affirmed.
Procedural Outcome
The legislative veto provision was rendered unenforceable. The decision applied to similar provisions throughout federal law.
Archival Note
This entry documents the judicial record in INS v. Chadha as preserved in the official reports. The decision addressed the constitutionality of the legislative veto and clarified the procedural requirements imposed by the Constitution on congressional action.