Thursday, May 23, 2013

Block v. Community Nutrition Institute case brief

Block v. Community Nutrition Institute case brief
467 U.S. 340, 104 S. Ct. 2450, 81 L. Ed. 2d 270 (1984)

CASE SYNOPSIS: Petitioner Secretary of Agriculture appealed the judgment of the United States Court of Appeals for the District of Columbia Circuit, which affirmed in part and reversed in part the holding of the district court. The court of appeals held that respondent consumers had standing to seek review of milk market orders issued by the Secretary under the authority of the Agricultural Marketing Agreement Act of 1937 (Act), 7 U.S.C.S. § 601 et seq.

FACTS: The consumers, along with milk handlers and a nonprofit organization, brought suit challenging a milk market order requiring that handlers make a compensatory payment on any portion of reconstituted milk that their records showed had not been used to manufacture surplus milk products. The Supreme Court reversed the court of appeals, holding that the consumers did not have standing to challenge the order. Congress only intended that producers and handlers have standing and preclusion of consumer suits did not threaten the realization of the fundamental objectives of the Act. Though rules of statutory construction generally favored judicial review of administrative action, the language and legislative history of the Act strongly indicated that Congress intended that judicial review of market orders be restricted. The Act's general purpose of consumer interest was not sufficient to support a finding of standing for the consumers in light of the Act's unequivocal restriction of an administrative remedy to milk handlers. The handlers were entitled to judicial review of milk market orders after exhausting the administrative remedies of the Act. 7 U.S.C.S. § 608(c)(15)(A).

CONCLUSION: The Court reversed the order of the court of appeals.

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