Train v. City of New York

Background

A group of cities led by the city of New York sued the Environmental Protection Agency after the President directed the EPA Administrator to withhold large portions of funds Congress had authorized for municipal sewage treatment. The 1972 law added a Title II program that authorized federal financial assistance equal to 75% of municipal sewer and treatment work costs and specified totals for three fiscal years. The Administrator allotted far less than the amounts Congress had authorized, and the cities sought a court order requiring full allotment.

Reasoning

The core question was whether the statute requires the Administrator to allot the full amounts Congress authorized or lets the Executive withhold part of those sums at the allotment stage. The Court read §205(a) and §207 together and concluded that sums “authorized to be appropriated” must be allotted; the qualifying phrase “not to exceed” in §207 did not mean Congress intended the Executive to withhold entire allotments. The Court found nothing in the statutory language or legislative history showing Congress meant to permit withholding at the allotment stage rather than at the later obligation stage. The Court therefore affirmed the lower courts and held the Administrator could not lawfully withhold the authorized allotments.

Real world impact

As a practical matter, the decision requires the EPA to make the larger allotments Congress authorized for municipal sewage projects, making more federal grant money immediately available to cities and towns that meet the statutory requirements. The ruling restrains Executive withholding at the allotment step and supports the goal of prompt federal funding for wastewater construction projects.

Dissents or concurrances

Justice Douglas joined the result but wrote only to concur in the outcome.