Lincoln v. Vigil
Citation: 508 U.S. 182 (1993) Court: Supreme Court of the United States
Facts
The Indian Health Service operated a clinical program providing diagnostic and treatment services to handicapped Native American children in the Southwest. Congress had appropriated funds to the IHS in a lump sum, without specifying that any portion must go to this program. The IHS terminated the program and redirected the funds to a nationwide effort. Vigil and other program recipients sought judicial review of the termination decision under the APA.
Issue
Whether an agency’s decision to terminate a program funded from a lump-sum appropriation is committed to agency discretion by law under APA §701(a)(2), and therefore unreviewable.
Holding
The Supreme Court unanimously held that the IHS’s decision to reallocate funds from the lump-sum appropriation was committed to agency discretion by law and thus not subject to judicial review under the APA.
Rule / Doctrine
An agency’s allocation of funds from a lump-sum congressional appropriation is committed to agency discretion under §701(a)(2). When Congress appropriates a lump sum without earmarking it for specific programs, it signals that the agency has discretion to determine how best to deploy those resources. There is no law to apply — no statutory directive against which to measure the agency’s allocation decision — so courts cannot review the choice.
Significance
Lincoln v. Vigil extends the “committed to agency discretion” doctrine into the budget and resource allocation context. It establishes that lump-sum appropriations signal congressional intent to give agencies broad spending discretion, insulating programmatic decisions from APA review. The case is important for understanding how the §701(a)(2) exception operates beyond pure enforcement non-prosecution decisions (compare Heckler v. Chaney) and into routine agency management choices.