Heckler v. Chaney
, , was a case heard before the United States Supreme Court
. The case presented the question of the extent to which a decision of an administrative agency, here the Food and Drug Administration
, to exercise its discretion not to undertake certain enforcement actions is subject to judicial review
under the Administrative Procedure Act
Respondents had been convicted in Oklahoma
criminal courts and sentenced to death. The procedure to be used was lethal injection
. They applied first to the FDA, stating that while the drugs to be involved in the lethal injection had been approved, the manner in which they were going to be used had not, in violation of statute. More simply, they were arguing that the FDA had not certified that the drugs were not "safe and effective" for human executions, and thus should be barred for being distributed via interstate commerce. The FDA refused to take the requested actions, thus the petitioners ultimately end up at the Supreme Court.
In the words of Justice Rehnquist, who delivered the opinion of the court, "[The Court]] granted certiorari
to review the implausible result that the FDA is required to exercise its enforcement power to ensure that states only use drugs that are 'safe and effective' for human execution..."
The Court assessed that the Court of Appeals decision coming before had addressed three questions:
- 1 - whether the FDA had jurisdiction to undertake the enforcement actions requested
- 2 - whether if it did have jurisdiction its refusal to take those actions was subject to judicial review, and
- 3 - whether if reviewable its refusal was arbitrary, capricious, or an abuse of discretion.