Clinton v. City of New York

1998-06-25

Headline: President’s line-item veto power struck down: Court invalidates law letting the President cancel parts of passed bills, blocking unilateral cancellations and protecting Congress’s lawmaking role and affected parties.

Holding: The Court ruled that the Line Item Veto Act’s cancellation procedures violate the Constitution’s Presentment Clause, so the President may not unilaterally cancel parts of duly enacted laws and those cancellations are invalid.

Real World Impact:

Prevents President from unilaterally canceling parts of duly enacted laws.
Restores Congress’s exclusive process for making, changing, or repealing laws.
Protects state budgets, hospitals, and smaller buyers relying on enacted tax or spending provisions.

Topics: line-item veto, budget rules, presidential power, tax benefits, separation of powers

Summary

Background

Congress passed the Line Item Veto Act in 1996, effective January 1, 1997. The President used that law on August 11, 1997, to cancel (make without legal force) one Medicaid-related spending provision affecting New York and one tax provision aimed at farmers’ cooperatives. Two groups sued: New York City and health-care providers challenging the Medicaid cancellation, and Snake River Potato Growers cooperative and an officer challenging the canceled tax benefit. The District Court held the Act unconstitutional and the cases reached the Supreme Court.

Reasoning

The main question was whether the President may, under a statute, unilaterally prevent parts of duly enacted laws from taking effect. The Court held that the Act’s cancellation procedure functionally repealed or amended enacted statutes because cancellations prevent provisions “from having legal force or effect.” That action bypasses the Constitution’s Presentment Clause, which requires bills approved by both Houses to be presented to the President as a whole and either signed or returned. The Court rejected arguments that historical delegations or the Act’s “lockbox” budget features made cancellations constitutional.

Real world impact

Because the Court found that plaintiffs had standing and that the Act violates the Presentment Clause, the President may not unilaterally cancel enacted spending items or limited tax benefits under this statute. The decision restores Congress’s exclusive procedure for changing enacted law and immediately affects the specific cancellations at issue and similar future attempts to repeal parts of laws by executive fiat.

Dissents or concurrances

Justice Breyer dissented, arguing the Act was constitutional and comparable to longstanding delegations; Justice Scalia and Justice Kennedy wrote separate opinions emphasizing other separation-of-powers concerns. These views explain the institutional debate but do not change the Court’s ruling.