Nat'l Wildlife Fed'n v. United States - 200 U.S. App. D.C. 53, 626 F.2d 917 (1980)

Rule:

Federal courts possess the discretionary power to withhold mandamus and declaratory relief. But where a federal official has a clear obligation to perform a ministerial duty, a federal district court may issue a writ of mandamus under 28 U.S.C.S. § 1361 to compel the fulfillment of the obligation. Mandamus is not precluded because the federal official at issue is the President of the United States.

Facts:

The Forest and Rangeland Renewable Resources Planning Act of 1974, Pub. L. No. 93-378, 88 Stat. 476, as amended (the Act), required the President and the administration to develop what is, in effect, a master plan for the management and use of forests and rangelands. The master plan was highly multifarious. Its components include a "Renewable Resource Assessment, a Renewable Resource Program, a system of annual reports, a presidential Statement of Policy, and various presidential budget statements. Appellant National Wildlife Federation, an environmental group, asserted the inadequacy of certain disclosures and explanations that accompanied the President's proposed fiscal 1979 budget in light of § 8(b) of the Forest and Rangeland Renewable Resources Planning Act (Act), 16 U.S.C.S. § 1606(b) (1976). Appellant then challenged the district court’s decision dismissing its action requesting declaratory relief and mandamus against appellee United States. 

Issue:

Did the district court properly decline appellant’s request for declaratory relief and mandamus against appellee?

Answer:

Yes.

Conclusion:

The court affirmed the decision of the federal district court on the ground of the discretionary power of the federal courts to withhold mandamus or a declaratory judgment sought by the appellant. The court found, on appeal, that public interest had dictated that courts exercise restraint in passing upon crucial issues. The court refused to intervene in wrangling over the federal budget and budget procedures, stating that such matters were best resolved through bargaining and accommodation between the legislative and executive branches. The court also noted, on the issue of the mootness exception for cases capable of repetition, yet evading review, that the exception required more than the mere capability of repetition. For several reasons, in addition to serious questions of justiciability, the court denied to provide relief: no legislator complained that the President's informational submissions violated the Act and the issue might never arise again.