Block v. Community Nutrition Institute
Citation: 467 U.S. 340 (1984) Court: Supreme Court of the United States
Facts
The USDA issued milk marketing orders under the Agricultural Marketing Agreement Act of 1937 (AMAA). Handlers and producers were expressly granted rights to challenge these orders through the statute’s administrative review scheme. Consumer groups, who were given no express review rights under the statute, sought judicial review of the marketing orders, claiming they raised prices illegally.
Issue
Whether consumers may obtain judicial review of USDA milk marketing orders under the APA when the governing statute expressly provides a review mechanism for handlers and producers but is silent as to consumers.
Holding
The Supreme Court held that the AMAA impliedly precluded consumer review. The comprehensive statutory scheme — which expressly granted review to specific parties — demonstrated Congress’s intent to limit review to those parties.
Rule / Doctrine
Implied preclusion of judicial review under APA §701(a)(1): where a comprehensive regulatory scheme expressly grants review rights to certain parties, courts may infer that Congress intended to preclude review by others not mentioned. The structure and purpose of the statutory scheme can rebut the presumption in favor of judicial review even without an explicit preclusion clause. Courts ask whether congressional intent to preclude review “may be inferred from the [statute’s] structure.”
Significance
Block v. Community Nutrition Institute is the leading case on implied preclusion of judicial review. It demonstrates that express preclusion language is not necessary — the architecture of a statutory scheme can itself communicate congressional intent to limit the class of reviewable parties. The case is regularly paired with Johnson v. Robison (express preclusion) and Webster v. Doe (constitutional claims surviving preclusion) in the administrative law judicial review unit.