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Carnahan v. Maloney

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Supreme Court of the United States
Carnahan v. Maloney
Docket number: 22-425
Term: 2023
Court: United States Supreme Court
Important dates
Dismissed: June 26, 2023
Court membership
Chief Justice John RobertsClarence ThomasSamuel AlitoSonia SotomayorElena KaganNeil GorsuchBrett KavanaughAmy Coney BarrettKetanji Brown Jackson

Carnahan v. Maloney is a case that was scheduled for argument before the Supreme Court of the United States during the court's October 2023-2024 term. The case concerned whether members of Congress have Article III standing to sue executive agencies regarding the disclosure of information. The judgment was vacated and the case was remanded to the United States Court of Appeals for the District of Columbia Circuit with instructions to dismiss the case on June 26, 2023, following a voluntary dismissal of the case by the plaintiffs in the district court.[1]

HIGHLIGHTS
  • The issue: The case concerned 5 U.S.C. 2954, which requires executive agencies to provide a response when information is requested by seven or more House Oversight Committee members. Click here to learn more about the case's background.
  • The questions presented: "Whether individual Members of Congress have Article III standing to sue an executive agency to compel it to disclose information that the Members have requested under 5 U.S.C. 2954."[2]
  • The outcome: The case was vacated and remanded to the United States Court of Appeals for the District of Columbia Circuit with instructions to dismiss the case.

  • The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit. To review the lower court's opinion, click here.

    Why it matters: The case was an example of the U.S. Supreme Court considering whether members of Congress had standing to sue executive agencies.

    Timeline

    The following timeline details key events in this case:

    Background

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    Judicial deference
    Nondelegation
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    Procedural rights
    Agency dynamics

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    A group of Democratic members of the United States House of Representatives Committee on Oversight and Accountability requested the disclosure of information from the General Services Administration (GSA) regarding an agreement from 2013 between the GSA and a company owned by President Donald Trump (R). The GSA had reportedly leased a government-owned building in Washington D.C. to the company which required congressional oversight, according to the group.

    Pursuant to 5 U.S.C. § 2954, the group in 2017 requested the GSA to disclose information regarding the agreement. The members of Congress argued that 5 U.S.C. § 2954 requires executive agencies to respond to information requests from seven or more members of the House Committee on Oversight and Accountability or five or more members of the United States Senate Committee on Homeland Security and Governmental Affairs. The GSA complied with sharing some of the documents requested but argued that other information requested was protected under the Freedom of Information Act (FOIA).

    In response, the members of the House Committee on Oversight and Accountability filed a lawsuit against the GSA in the United States District Court for the District of Columbia, which was dismissed on the basis that the members of Congress did not have Article III standing.

    The group appealed the decision to the United States Court of Appeals for the District of Columbia Circuit. The divided court reversed and remanded the decision, arguing that the members of Congress did have standing to take legal action against the GSA.

    The United States Supreme Court agreed to hear the case in the October 2023-2024 term.[3][4]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    Whether individual Members of Congress have Article III standing to sue an executive agency to compel it to disclose information that the Members have requested under 5 U.S.C. 2954."

    [5]

    Oral argument

    The case was dismissed before oral argument.[6]

    Outcome

    The judgment was vacated and the case was remanded to the United States Court of Appeals for the District of Columbia Circuit with instructions to dismiss the case.

    Justice Ketanji Brown Jackson dissented from the decision to vacate the lower court’s decision, arguing instead to “dismiss the writ of certiorari as improvidently granted.”[6]

    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]


    See also

    External links

    Footnotes