INS v. Chadha
Citation: 462 U.S. 919 (1983) Court: Supreme Court of the United States
Facts
Jagdish Rai Chadha, a Kenyan national, was ordered deported after overstaying his student visa. An immigration judge suspended his deportation under a statutory provision allowing such relief, but the House of Representatives exercised a one-house legislative veto to overrule that suspension, as permitted by the Immigration and Nationality Act. Chadha challenged the constitutionality of the one-house veto provision, arguing it violated the structural requirements of Article I.
Issue
Whether a one-house legislative veto — allowing either chamber of Congress to overturn an executive agency’s decision without presenting the action to the other chamber or the President — is constitutional under Article I.
Holding
The one-house legislative veto is unconstitutional because any congressional action with the force of law must satisfy the bicameralism and presentment requirements of Article I.
Rule
Any action by Congress that has the “purpose and effect of altering the legal rights, duties, and relations of persons” outside the legislative branch must comply with Article I’s requirements of bicameral passage and presentment to the President — there are no shortcuts to lawmaking.
Significance
Chadha invalidated hundreds of legislative veto provisions spread across federal statutes, fundamentally reshaping the relationship between Congress and the executive branch. The decision reinforced the formalist understanding of separation of powers: each branch must stay within its constitutionally prescribed channels. It made it significantly harder for Congress to retain ongoing supervisory control over delegated executive power without going through the full legislative process. The case is central to administrative law discussions about the nondelegation doctrine and congressional oversight mechanisms, and it remains a foundational case for understanding the limits of legislative control over agency action.