Friday, February 1, 2013

Robertson v. Seattle Audubon Society case brief

Robertson v. Seattle Audubon Society case summary
503 U.S. 429

PROCEDURAL HISTORY:
The petitioners in this case appealed the Ninth Circuit court's ruling that stated that the Department of the Interior and Related Agencies Appropriations Act was unconstitutional.
The petitioners contended that the lower court had improperly ruled that §318 violated Article III of the Constitution of the United States by impermissibly directing a specific judicial decision without amending or repealing the statutes that are underlying the litigation.

FACTS:
-Respondents filed various suits under multiple statutes that challenged the petitioners' allowance of the harvesting and sale of timber from old growth forests.
-In response to this, Congress enacted §318 of the Department of the Interior and Related Agencies Appropriations Act, which, among other things, stated that Congress determined and directed that management of the forests according to §§318(b)(3) and (b)(5) was adequate consideration for the purpose of meeting the statutory requirements that were the basis for respondents' underlying suits.
-Consolidated appeals were filed from the trial courts' decisions, which upheld §318 as constitutional. -The appeals court reversed.
-On certiorari, the higher court reversed.
-The court rejected the respondents' contention that §318 impermissibly directed a particular judicial decision without repealing or amending the statutes underlying the suits.
-Instead, the court ruled that, in replacing the legal standard that was applicable to the pending suits, §318 merely compelled changes in the law and not results under the old law.
-The section did not direct courts to make any particular findings of fact nor any applications of law to fact.
-Thus, the statute did not violate Article III of the Constitution.

CONCLUSION:
The court reversed the judgement. 
The provision merely amended the old law.

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