Lincoln v. Vigil case
brief
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508 U.S. 182, 113 S. Ct.
2024, 124 L. Ed. 2d 101 (1993)
CASE SYNOPSIS:
Respondents, children eligible to receive services (recipients)
through the Indian Children's Program (program), filed an action
against petitioner, Acting Director of the Indian Health Service
(agency), after the agency discontinued the program. The district
court granted summary judgment to the recipients and the United
States Court of Appeals for Tenth Circuit affirmed. The agency filed
a petition for writ of certiorari.
FACTS: The agency discontinued the program, which provided medical services to handicapped Indian children in the Southwest, after it decided to reallocate the programs' resources to a nationwide effort to assist such children. The recipients filed an action, alleging that the agency's decision to discontinue direct clinical services violated various federal laws, various agency regulations, and the Fifth Amendment's due process clause. The district court granted summary judgment for the recipients and the appellate court affirmed, rejecting the agency's argument that the decision to discontinue the program was committed to agency discretion under the Administrative Procedure Act (APA). The Court granted the agency's petition for writ of certiorari, holding that the agency's decision was not subject to judicial review under § 701 of the APA, specifically 5 U.S.C.S. § 701(a)(2), because the agency's decision to discontinue the program was "committed to agency discretion by law." The agency's decision was discretionary because it pertained to the allocation of funds from a lump-sum appropriation, and the allocation of funds met permissible statutory objectives.
CONCLUSION: The Court reversed the grant of summary judgment to the recipients and remanded the case for further proceedings.
FACTS: The agency discontinued the program, which provided medical services to handicapped Indian children in the Southwest, after it decided to reallocate the programs' resources to a nationwide effort to assist such children. The recipients filed an action, alleging that the agency's decision to discontinue direct clinical services violated various federal laws, various agency regulations, and the Fifth Amendment's due process clause. The district court granted summary judgment for the recipients and the appellate court affirmed, rejecting the agency's argument that the decision to discontinue the program was committed to agency discretion under the Administrative Procedure Act (APA). The Court granted the agency's petition for writ of certiorari, holding that the agency's decision was not subject to judicial review under § 701 of the APA, specifically 5 U.S.C.S. § 701(a)(2), because the agency's decision to discontinue the program was "committed to agency discretion by law." The agency's decision was discretionary because it pertained to the allocation of funds from a lump-sum appropriation, and the allocation of funds met permissible statutory objectives.
CONCLUSION: The Court reversed the grant of summary judgment to the recipients and remanded the case for further proceedings.
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