Train v. City of New York

Appellant
Russell E. Train, Administrator, Environmental Protection Agency
Appellee
City of New York
Appellant's Claim
That the Environmental Protection Agency (EPA) did not have to allot federalfunds in their entirety to states according to the Federal Water Pollution Control Act Amendments of 1972.
Chief Lawyer for Appellant
Robert H. Bork, U.S. Solicitor General
Chief Lawyer for Appellee
John R. Thompson
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger, William O. Douglas, Thurgood Marshall, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart, Byron R. White (writing for the Court)
Justices Dissenting
None
Place
Washington D.C.
Date of Decision
18 February 1975
Decision
The EPA had to disburse funds in their entirety to states seeking financial assistance under the Federal Water Pollution Control Act; Court of Appeals forthe District of Columbia Circuit decision affirmed.
Significance
That despite a presidential veto of the sum of moneys to be disbursed to states, the EPA was required to disburse the maximum allotments set forth in theCongressional Amendments to the Water Pollution Control Act.
The Federal Water Pollution Control Act was designed to help mitigate water pollution around the country. In 1972 the act was amended to provide financialassistance to states for improvements made to their sewers and sewage treatment plants. For this purpose, section 207 of the amendments designated maximum amounts of 5 million dollars and 6 million dollars to be allocated for fiscal years 1973 and 1974 respectively. The administrator for the EnvironmentalProtection Agency was responsible for disbursing these funds according to a schedule set forth in section 205 (a) of the amendments. Congress passed the Amendments on 4 October 1972 and President Richard Nixon vetoed them on 17 October 1972. Even though Congress overrode the veto, President Nixon wrote a letter to the EPA administrator directing him to disburse only 2 million dollars and 3 million dollars for fiscal years 1973 and 1974 respectively.
When the administrator abided by the president's directive, the city of New York filed a class action suit seeking the 5 million dollar and 6 million dollar maximums due the municipality according to the Congressional Amendments. The city of New York brought their case before the District Court of the District of Columbia. A motion by the EPA to dismiss the suit was denied in May of1973. After the district court granted the city of New York a summary judgment, the court of appeals found that the Water Pollution Control Act "requiresthe Administrator to allot the full sums authorized to be appropriated" according to section 207 of the amendments. Administrator Train promptly asked the U.S. Supreme Court to review the decision.
Petition for a Writ of Certiorari
The Supreme Court granted Train's request for a review, a process called a petition for a writ of certiorari. Train maintained that the language ofsection 205 (a) setting forth the disbursement duties of the administrator provides for a maximum dollar amount, not a minimum to be provided to the states. As evidence, he quoted the original legislation, which stated that: "allsums authorized to be appropriated pursuant to [section 207] . . . shall be allotted by the Administrator." In the legislation actually enacted into law as the 1972 amendments, the word "all" was deleted. Train argued that the omission of the word all meant that he need not allot the maximum amounts. Duringthe Supreme Court review, Justice White wrote in the opinion of the Court:

The Administrator's arguments based on the statutory language andits legislative history are unpersuasive . . . It appears to us that the word`sums' has no different meaning and can be ascribed no different function inthe context of [section] 205 than would the words `all sums.'

In affirming the court of appeals decision, the Supreme Court also found thatthe legislative text did not provide for executive intervention. Although the wording of the amendments was altered slightly from first draft to enactment, this was not sufficient justification for President Nixon's directive concerning diminished financial assistance. Justice White opined, "we cannot accept the . . . deletion of the one word from [section] 205 (a) as altering theentire complexion and thrust of the Act." Thus, Train was responsible for disbursing the maximum amounts described in the 1972 amendments of the Water Pollution Control Act to the city of New York.
Related Cases

• Huron Portland Cement Co. v. City of Detroit, 362 U.S. 440 (1960).
  
• Philadelphia v. New Jersey, 430 U.S. 141 (1977).

The Environmental Protection Agency
The Environmental Protection Agency is an independent agency within the U.S.government established in 1970. At that time the EPA's budget was roughly $1billion; the EPA's current budget is nearly $8 billion. The current administrator of the EPA is Carol M. Browner. The EPA sets standards for environmentalprotection and monitors businesses to see that these standards are maintained. The EPA conducts research, offers grants, and monitors the activity of environmentally suspect industries, and oversees the impact of other federal agencies on the environment. Among its accomplishments the EPA has curbed pollution of the air and water, regulated hazardous waste disposal sites, cooperated in a world wide effort to limit the substances that deplete the ozone layer, and fined companies for violations of standards established by the EPA.
In recent years one of the central functions of the EPA has been administering the Comprehensive Environmental Response, Compensation and Liability Act of1980, commonly known as Superfund. Congress initially approved $1.6 billionfor the fund which was designed to clean up hazardous waste sites. In the early 1980s the agency was investigated by Congress for allegations of the misuse of funds in the Superfund project.
Sources
www.epa.gov