Heckler v. Chaney

Heckler v. Chaney was a unanimous decision by the U.S. Supreme Court holding, that the FDA's decision not to enforce drug laws against lethal injections used for capital punishment was not reviewable under the Administrative Procedure Act.

Then-Justice William Rehnquist (not yet Chief Justice) wrote the decision for the Court (which not all Justices joined), including:

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We therefore conclude that the presumption that agency decisions not to institute proceedings are unreviewable under 5 U.S.C. § 701(a)(2) is not overcome by the enforcement provisions of the FDCA. The FDA's decision not to take the enforcement actions requested by respondents is therefore not subject to judicial review under the APA. The general exception to reviewability provided by § 701(a)(2) for action "committed to agency discretion" remains a narrow one, see Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402 (1971), but within that exception are included agency refusals to institute investigative or enforcement proceedings, unless Congress has indicated otherwise. In so holding, we essentially leave to Congress, and not to the courts, the decision as to whether an agency's refusal to institute proceedings should be judicially reviewable. No colorable claim is made in this case that the agency's refusal to institute proceedings violated any constitutional rights of respondents, and we do not address the issue that would be raised in such a case. Cf. Johnson v. Robison, 415 U.S. 361, 366 (1974); Yick Wo v. Hopkins, 118 U.S. 356, 372-374 (1886). The fact that the drugs involved in this case are ultimately to be used in imposing the death penalty must not lead this Court or other courts to import profound differences of opinion over the meaning of the Eighth Amendment to the United States Constitution into the domain of administrative law.

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Heckler v. Chaney, 470 U.S. 821, 837-38, 105 S. Ct. 1649, 1659 (1985).