Sunday, October 27, 2013

Darby v. Cisneros case brief summary

Darby v. Cisneros case brief summary
509 U.S. 137 (1993)

Petitioners filed suit, seeking an injunction and a declaration that administrative sanctions were imposed for purposes of punishment in violation of the Housing and Urban Development's debarment regulations. The district court denied respondents' motion to dismiss and granted petitioners' motion for summary judgment. Certiorari was granted to the United States Court of Appeals for the Fourth Circuit, which reversed the district court.

Petitioners claimed that administrative sanctions were imposed for the purposes of punishment and were therefore not in accordance with law within the meaning of § 10(e)(B)(1) of the Administrative Procedure Act (APA). Respondents claimed that petitioners had failed to exhaust administrative remedies and argued that federal courts remained free under the APA to impose appropriate exhaustion requirements.

-Courts were not free to impose an exhaustion requirement as a rule of judicial administration where agency actions had already become "final" under § 10(c) of the APA.
-The Court held that the exhaustion doctrine continued to apply as a matter of judicial discretion in cases not governed by the APA.
-However, where the APA was applicable, an appeal to superior agency authority was a prerequisite to judicial review only when expressly required by statute, or when an agency rule required appeal before review and the administrative action was made inoperative pending that review.


The Court reversed the appellate court's decision and remanded for further proceedings.

Recommended Supplements for Administrative Law
Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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