Immigration & Naturalization Service v. Chadha case brief

Immigration & Naturalization Service v. Chadha case brief

462 U.S. 919, 103 S. Ct. 2764, 77 L. Ed. 2d 317 (1983)

CASE SYNOPSIS: Petitioner appealed the decision of the United States Court of Appeals for the Ninth Circuit holding unconstitutional the provision in § 244(c)(2) of the Immigration and Nationality Act, 8 U.S.C.S. § 1254(c)(2), authorizing one House of Congress to invalidate the decision of the Executive Branch, pursuant to authority delegated by Congress to the Attorney General, to allow respondent deportable alien to remain in the United States.

FACTS: Respondent deportable alien initially brought an action to challenge the constitutionality of the provision in § 244(c)(2) of the Immigration and Nationality Act (Act), 8 U.S.C.S. § 1254(c)(2), authorizing the House of Representatives, by resolution, to invalidate the decision of the Executive Branch, pursuant to authority delegated by Congress to the Attorney General, to allow respondent to remain in the United States. The lower court held that the House was without constitutional authority to order respondent alien's deportation because § 244(c)(2) violated the doctrine of separation of powers. 

DISCUSSION

• The U.S. Supreme Court affirmed and held that the House's action pursuant to § 244(c)(2) was legislative in function and did not fit within any exceptions authorizing one House to act alone. 
• As a result, the House's action was subject to certain checks contained in U.S. Const. art. I, such as the bicameral requirement, presentment to the President, and the Presidential veto. 
• Because the House failed to act in conformity with the express procedures for enacting legislation, the Court held that the congressional veto provision in § 244(c)(2) was severable from the Act and unconstitutional.

CONCLUSION: The Supreme Court affirmed and held that the House's action was legislative in function and did not fit within any exceptions authorizing one House of Congress to act alone. Because the House failed to act in conformity with the express constitutional procedures for enacting legislation, the Court held that the congressional veto provision was unconstitutional, but severable from the rest of the Immigration and Nationality Act.

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