Brief Fact Summary. To offset rising government budget deficits, Congress passed the Gramm-Rudman-Holings Act (the Act), which gave the Comptroller General authority to mandate spending reductions if certain estimated target deficits were exceeded.
Synopsis of Rule of Law. Congress cannot reserve for itself power of removal of an officer charged with the execution of the laws except by impeachment.
Issue. Did the assignment by Congress to the Comptroller General of the United States of certain functions under the Act violate the separation of powers doctrine?
Held. Yes. The judgment and order of the District Court are affirmed.
Under the statute, the Comptroller must exercise judgment concerning facts that affect the application of the Act. The Comptroller’s duties are not merely “ministerial and mechanical.” Interpreting a law to implement legislative mandate is the very essence of “execution” of the law.
To permit the execution of the laws to be vested in an officer answerable only to Congress would essentially reserve in Congress control over the execution of laws. Congress cannot grant to an officer under its control powers it does not itself have. Otherwise, Congress could remove or threaten to remove an officer for executing laws in a way contrary to what Congress desires.
Concurrence. Justice John Paul Stevens wrote that the Act is unconstitutional because the Comptroller General must be characterized as an agent of Congress. Therefore, it must follow the procedures mandated in Article One of the United States Constitution (Constitution) regarding lawmaking.
While the Constitution diffuses power the better to secure liberty, it also contemplates that practice will integrate the dispersed powers into a workable government.View Full Point of Law