Clinton v. City of New York
Citation and Court
Clinton v. City of New York, 524 U.S. 417 (1998). United States Supreme Court.
Facts
The Line Item Veto Act of 1996 authorized the President to cancel specific dollar amounts of discretionary budget authority and limited tax benefits after signing them into law. President Clinton used this authority to cancel a provision of the Balanced Budget Act that benefited New York City’s Medicaid program and a provision of the Taxpayer Relief Act benefiting the food processing industry. Affected parties sued, challenging the Act’s constitutionality.
Issue
Whether the Line Item Veto Act unconstitutionally grants the President the power to amend or repeal acts of Congress.
Holding
The Supreme Court struck down the Line Item Veto Act six-to-three. The President’s cancellation of enacted statutory provisions was the functional equivalent of repealing a law, which may be accomplished only through the constitutionally prescribed procedures of bicameralism and presentment.
Rule / Doctrine
Under the Presentment Clause, legislation is valid only if passed by both houses of Congress and either signed by the President or enacted over a presidential veto. A statute that permits the President to cancel portions of enacted law after signing — effectively amending what was passed — violates this procedure. There is no constitutional mechanism for a unilateral presidential line-item veto.
Significance
Clinton v. City of New York is the definitive ruling on presidential power to selectively repeal enacted legislation. It enforces strict formalism in the legislative process and has been cited as a limit on structural arrangements that allow the executive to alter the legal status quo without going through Article I procedures. The case also confirmed that Congress cannot simply delegate away its legislative power in ways that circumvent bicameralism.