Department of Transportation v. Association of American Railroads

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Administrative Law
  • Date Filed: March 9, 2015
  • Case #: No. 13–1080
  • Judge(s)/Court Below: Kennedy, J., delivered the opinion of the Court, in which Roberts, C. J., and Scalia, Ginsburg, Breyer, Alito, Sotomayor, and Kagan, JJ., joined. Alito, J., filed a concurring opinion. Thomas, J., filed an opinion concurring in the judgment.
  • Full Text Opinion

When Amtrak assists the Federal Railroad Administration (FRA) in creating metrics and standards for rail travel it is acting as a government entity.

After Congress created the National Railroad Passenger Corporation, (Amtrak) in 1970 it granted Amtrak and the FRA joint authority over metrics and standards that deal “that address the performance and scheduling of passenger railroad services.” Respondent sued Petitioner alleging that Congress’ delegation of join authority to Amtrak was a violation of the separate of powers doctrine of the constitution, as well as, the Due Process Clause of the Fifth Amendment.

Both of Respondent’s claims were rejected by the district court. On appeal to the D.C. Circuit, the Court of Appeals reversed, holding that because Amtrak was a private corporation, Congress violated the doctrine of non-delegation by allowing it joint authority in creating metrics and standards. After granting certiorari, he Supreme Court held that when Amtrak is acting in its regulatory capacity it is acting as a government entity and thus Congress’ delegation of authority does not violated the non-delegation doctrine. However, the Court remanded the case back down to reserve lingering question of the lawfulness of some of the metrics and standards that Amtrak helped create.

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