ICC v. Locomotive Engineers
Citation: 482 U.S. 270 (1987) Court: Supreme Court of the United States
Facts
The Interstate Commerce Commission reversed an Administrative Law Judge’s finding on the interpretation of a safety rule affecting locomotive engineers. The Brotherhood of Locomotive Engineers challenged the ICC’s reversal as arbitrary and capricious. The central question was whether the ICC’s decision was subject to judicial review under the APA or fell within the “committed to agency discretion” exception.
Issue
Whether the ICC’s reversal of an ALJ’s safety rule interpretation is subject to judicial review under the APA, or whether it falls within the §701(a)(2) exception for action “committed to agency discretion by law.”
Holding
The Supreme Court held that the “committed to agency discretion” exception under §701(a)(2) applies when there is truly no law to apply — that is, no meaningful standard against which a court can measure the agency’s exercise of discretion.
Rule / Doctrine
APA §701(a)(2) precludes judicial review when a statute is drawn in terms so broad that there is no law to apply. Courts ask whether there is a meaningful standard against which to measure agency action; if no such standard exists, review is unavailable. This is a narrow exception, reserved for situations of genuine legal vacuum.
Significance
ICC v. Locomotive Engineers clarifies the scope of the “no law to apply” test from Citizens to Preserve Overton Park v. Volpe (1971). The case confirms that the committed-to-discretion exception is genuinely narrow and that most agency action remains reviewable because some legal standard — statutory text, legislative history, or agency regulations — will usually provide a meaningful benchmark. It is frequently paired with Webster v. Doe when teaching the §701(a)(2) exception.