American Trucking Associations, Inc. v. United States
United States Court of Appeals for the District of Columbia Circuit · 1980 · Administrative Law
Administrative LawICCinterventionmotor carrier licensinginterested personsagency procedurearbitrary and capriciousAPA
Facts
The ICC had long allowed virtually anyone to protest a motor carrier application and participate without showing any interest, but a large influx of applications created a substantial backlog. After rulemaking, the ICC adopted new rules granting automatic intervention to supporting parties and to carriers that showed authority, capability, and actual service within the scope of the application, while allowing others to seek permissive intervention under listed factors. Petitioners argued the rules unlawfully restricted intervention rights of competitors and labor representatives. The ICC defended the rules as a docket-management measure that still preserved intervention for genuinely interested persons.
Issue
Whether the ICC's new intervention regulations for motor carrier licensing proceedings facially violate the Interstate Commerce Act, the Administrative Procedure Act, or due process by restricting intervention, or are arbitrary, capricious, or an abuse of discretion.
Rule
Where Congress expressly delegates authority to an agency to prescribe regulations governing intervention and procedure, the agency may require would-be intervenors to demonstrate a sufficient interest rather than granting automatic participation to all comers. Such procedural rules will be upheld unless they facially deny participation to persons with a statutory right to intervene or are arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.
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Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
The Federal Freight Licensing Board, a federal agency, adopts a rule for entry proceedings. The rule grants automatic intervention only to carriers that show current authority, operational capability, and actual service in the market at issue, while requiring all other opponents to file petitions showing their interest. A trade group in Chicago files a facial challenge, arguing the governing statute's reference to 'interested persons' entitles every potential competitor to automatic party status.
How should a court most likely rule on the facial challenge?
Explanation. The majority held that where Congress expressly delegates authority to prescribe regulations governing intervention and procedure, the agency may use a mechanism to determine whether a would-be intervenor has the requisite interest. The key distinction is between a right to intervene and a right to automatic intervention; the statute protects the former, not necessarily the latter. A facial challenge fails so long as the rules, fairly interpreted, do not deny participation to genuinely interested persons.