Patchak v. Jewell

United States Court of Appeals for the District of Columbia Circuit · 2016 · Federal Courts

Federal Courtsjurisdiction strippingArticle IIIseparation of powerspending casesnew lawAdministrative Procedure ActIndian Reorganization Act

Facts

Patchak sued under the APA challenging the Department of the Interior's authority under the IRA to take the Bradley Property into trust for the Gun Lake Tribe. While the case was pending after remand from the Supreme Court, Congress enacted the Gun Lake Act, which reaffirmed the land as trust land, ratified and confirmed the Secretary's action, and provided that any action relating to that land could not be filed or maintained in federal court and had to be promptly dismissed. Patchak argued the Act was unconstitutional under Article III, the First Amendment, the Fifth Amendment, and the Bill of Attainder Clause. He also challenged the district court's refusal to strike a supplemental administrative record entry referencing a later Interior notice.

Issue

Whether the Gun Lake Act constitutionally stripped the federal courts of jurisdiction over Patchak's pending suit relating to the Bradley Property. Also, whether the district court abused its discretion in denying Patchak's motion to strike the supplement to the administrative record.

Rule

Congress may affect pending litigation by changing the law, including by withdrawing subject matter jurisdiction over a defined class of cases, provided it supplies new law rather than directing courts to reach a result under preexisting law. A jurisdiction-stripping statute is not unconstitutional merely because it targets a single pending case, and such a statute does not violate the Petition Clause, due process, or the Bill of Attainder Clause where Congress validly limits inferior federal court jurisdiction, the legislative process supplies all process due for changes to a pending cause of action, and the statute is nonpunitive.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Carver sued in federal district court in New Mexico under the APA, alleging that the Department of the Interior unlawfully placed a specific tract near Farmington into federal trust status for a tribal community. While the suit was pending, Congress enacted a stand-alone statute providing that any action, including pending actions, relating to that named tract may not be filed or maintained in federal court and must be promptly dismissed.

Nina argues the statute violates Article III because Congress effectively ended her pending case. How should the court rule?

Explanation. The majority held that Congress may affect pending litigation by changing the law, including by withdrawing inferior federal court jurisdiction over a defined class of cases. A statute requiring dismissal of actions relating to identified land supplies a new legal standard and does not violate Article III merely because it ends a pending suit. Congress need not amend the underlying APA or other substantive statute directly. (Derived from Patchak v. Jewell (n.d.).)