UNITED STATES ARMY CORPS OF ENGINEERS, ET AL., PETITIONERS V. AMERON, INC., ET AL. No. 87-163 In the Supreme Court of the United States October Term, 1987 On Petition for a Writ of Certiorari to the United States Court of Appeals for the Third Circuit Reply Brief for the Petitioners We demonstrated in the certiorari petition that the stay provisions of the Competition in Contracting Act (CICA), 31 U.S.C. (Supp. III) 3553 and 3554 -- which authorize the Comptroller General, an agent of Congress, to control the timing of the award or performance of a contract between an Executive Branch agency and a private party -- violate the separation of powers under the Constitution. The court of appeals' decision sustaining those provisions conflicts with INS. v. Chadha, 462 U.S. 919 (1983), which held that Congress may not take action that affects the legal "rights, duties, and relations" of Executive Branch officials and private parties except by passing a law (id. at 952), and with Bowsher v. Synar, No. 85-1377 (July 7, 1986), which held that the Comptroller General "may not be entrusted with executive powers" (slip op. 16) or "intrud(e) into the executive function" (id. at 18). Respondents' attempts to defend the court of appeals' decision in the face of Chadha and Synar are without merit. Respondents' contention that the court of appeals' decision does not in any event warrant review by this Court is also without merit. The question of the constitutionality of the CICA stay provisions is of broad practical importance because those provisons are triggered with respect to several thousand government contract actions annually. The constitutional question is ripe for resolution in this case, because the Executive and Legislative Branches have taken firm and formal positions on the constitutional question and have consistently regarded this as the leading case for its resolution. 1. Respondents' principal contention in support of the constitutionality of the CICA stay provisions is that they resemble the so-called "report-and-wait" mechanism that the Court found to be constitutional in Sibbach v. Wilson & Co., 312 U.S. 1, 14-15 (1941); INS v. Chadha, 462 U.S. at 935 n.9; and Alaska Airlines, Inc. v. Brock, No. 85-920 (Mar. 25, 1987), slip op. 11 & n.12. See Sen. & Ameron Br. in Opp. 4, 7-12; House Br. in Opp. 7, 13, 16. The report-and-wait device, however, is very different from the CICA provisions at issue here. a. Under a report-and-wait provision, an agency must report a particular administrative action to Congress, and the effective date of the administrative action then is postponed for a specified period during which Congress is afforded an opportunity to overturn that action by passing a law. In Sibbach, for example, the Court discussed a statute that provided that certain rules of civil procedure "shall not take effect until they shall have been reported to Congress by the Attorney General at the beginning of a regular session thereof and until after the close of such session." See 312 U.S. at 8, quoting Act of June 19, 1934, ch. 651, Session 2, 48 Stat. 1064. Similarly, in Chadha, the Court observed that after severance of the legislative veto, the statutory section there resembled the report-and-wait provision discussed in Sibbach, because suspensions of deportation would continue to be reported by the Attorney General to Congress but would not take effect until the expiration of the following session of Congress. See 462 U.S. at 935 & nn.8, 9, citing 8 U.S.C. 1254(c) (2). And the statute involved in Alaska Airlines required the Secretary of Labor to transmit certain proposed regulations to the transportation committees of the Senate and House of Representatives and to wait 30 "legislative days" -- defined to mean days during which both the House and Senate were in session -- before issuing the regulations in final form. Slip op. 11 & n.12, citing 49 U.S.C. App. 1552(f) (3). Thus, the report-and-wait provisions discussed by the Court in Sibbach, Chadha and Alaska Airlines each mandated the postponement of administrative action for a statutorily specified period of time. Those provisions are constitutional precisely because, unlike CICA, they do not delegate to one House of Congress (or to an agent of Congress, such as the Comptroller General) the power to decide on a case-by-case basis how long the stay of a particular administrative decision will last. The Constitution authorizes no delegation of power to an official of the Legislative Branch to modify the performance of an Executive function in any particular instance in which he sees fit. b. The Senate and Ameron contend (Br. in Opp. 2-3, 9-10) that the report-and-wait provisions discussed in Sibbach, Chadha and Alaska Airlines were comparable because the length of the postponement of the administrative action was determined by Congress's adjournment from day to day or at the close of a session. This contention is without merit for a number of reasons: First, the Constitution expressly grants each House of Congress the power to "adjourn from day to day" (Art. I, Section 5, Cl. 1), although bicameral action is required for any adjournment of more than three days (Art. I, Section 5, Cl. 4); and a resolution of adjournment is expressly excepted from the requirement of presentment to the President (Art. I, Section 7, Cl. 3). Thus, although the Senate and Ameron are correct that the stay imposed by a report-and-wait provision may constitutionally be terminated as a result of action by Congress that does not satisfy the bicameralism or presentment requirement of Article I, that is only because the congressional action in question -- adjournment -- is expressly excepted from those requirements. Compare Chadha, 462 U.S. at 955-956; Synar, slip op. 7. The report-and-wait provisions at issue in Sibbach, Chadha and Alaska Airlines therefore furnish no support for the notion that stay-terminating power may be vested in the Comptroller General, whose actions are not covered by any such exception to the bicameralism and presentment requirements. Second, the adjournment of a session of Congress (as in Sibbach and Chadha) or the adjournment of both Houses of Congress at the close of a specified "legislative day" (as in Alaska Airlines) is an objectively ascertainable event of independent public significance, and it occurs without reference to any particular administrative action that might have been reported to Congress. By contrast, the termination of the waiting period under CICA occurs by virtue of action by the Comptroller General that directly relates to the particular government contact, so that CICA effectively gives him discretion to determine when it shall commence. Third, the principal purpose of a report-and-wait provision is to afford Congress the opportunity to overturn the administrative action through the exercise of its "legislative Powers" under Article I -- i.e., through the passage of a law by bicameral action and presentment to the President. See Sibbach, 312 U.S. at 15-16 & n.17; Chadha, 462 U.S. at 935 & nn.8, 9; Alaska Airlines, slip op. 11 & n.12. Because adjournment terminates the occasions on which Congress may exercise its legislative powers, adjournment provides an appropriate statutory benchmark for terminating the stay of administrative action under a report-and-wait provision. By contrast, the Comptroller General cannot under Synar be given the power to make a binding decision affecting a government contract (see Pet. 18 n.9), and there accordingly is no constitutional basis for linking the termination of a stay under CICA to any action of the Comptroller General -- there is no valid legislative action the Executive is being to required to wait for. 2. Respondents also appear to contend (Sen. & Ameron Br. in Opp. 8-9; Comp. Gen. Br. in Opp. 6-7) that the length of the stay under CICA is wholly unrelated to the Comptroller General's determination of the merits of the bid protest, and that for this reason CICA does not mandate an impermissible intrusion by the Comptroller General into the execution of the procurement laws. But the Comptroller General's authority to dismiss a protest at the outset if it is "frivolous" or "does not state a valid basis for protest" (31 U.S.C. (Supp. III) 3554(a) (3)) directly ties the length of a stay to the Comptroller General's assessment of the merits. And the length of time the Comptroller General takes to resolve any protest necessarily will be determined in large part by his assessment of the merits, and the stay is in fact lifted only when the Comptroller General issues his decision on the merits. Indeed, respondents make essentially no effort to rebut our showing, based on repeated statements in the legislative history (see Pet. 23-24), that the very purpose of the CICA bid-protest provisions was to enable the Comptroller General to intervene in the execution of the procurement laws. For the foregoing reasons, the CICA stay provisions are constitutionally indistinguishable from the statute at issue in AFGE v. Pierce, 697 F.2d 303, 306 (D.C. Cir. 1982), which barred an executive department from using appropriated funds for a reorganization without the prior approval of the Appropriations Committees of the House and Senate. The D.C. Circuit held that statute unconstitutional because it delegated to committees of Congress the power to lift a statutory restriction. Similarly here, Congress has unconstitutionally delegated legislative power to the Comptroller General to lift a congressionally imposed restriction on the award or performance of a government contract. The decision of the Third Circuit sustaining such an arrangement therefore conflicts with the D.C. Circuit's decision in AFGE v. Pierce. The Senate and Ameron attempt to distinguish AFGE v. Pierce on the ground (Br. in Opp. 8 n.8) that the statute there gave the congressional committees the power "to dictate the substantive obligations of the executive," while CICA requires executive agencies to suspend their activities "temporarily," until the Comptroller General acts. However, the statute in AFGE v. Pierce did not authorize the congressional committees to "dictate" executive action; the committees were only authorized to free the executive agency to pursue the particular action if it wished to do so, just as the lifting of a stay under CICA frees the executive agency to proceed with the contract. The fact that the committees' lifting of the statuory restriction in AFGE v. Piece might have been coupled with an expression of "approval" is constitutionally irrelevant, and indeed in this case the Comptroller General likewise expressed his approval of the pertinent executive action (the Corps of Engineers' award of the contract to Spiniello) when he issued his decision that lifted the statutory stay. See Pet. 7-8. 3. In seeking to avoid the controlling force of Synar, respondents seize upon the Court's statement that the Comptroller General there was given the "ultimate authority" to determine budget cuts. Slip op. 17. This case is different, respondents contend, because the contracting agency is not required to follow the Comptroller General's decision on the bid protest. See Sen. & Ameron Br. in Opp. 2, 6; House Br. in Opp. 14, 16. Respondents misapprehend the import of Synar. The issue in Synar concerned the substance of the budget cuts, and the statutory provision in question was unconstitutional because the Comptroller General's determination of that question was controlling on the Executive Branch. This case concerns the timing of executive action, and under CICA, the Comptroller General, not the responsible executive agency, has "ultimate authority" over that issue for as long as a bid protest is pending. /1/ Congress's retention of such control in its agent likewise violates the separation of powers, because "as Chadha makes clear, once Congress makes its choice in enacting legislation, its participation ends. Congress can thereafter control the execution of its enactment only indirectly -- by passing new legislation." Synar, slip op. 18. 4. Contrary to respondents' contention (Sen. & Ameron Br. in Opp. 14-15; House Br. in Opp. 17; Comp. Gen. Br. in Opp. 7-8), this Court's decisions in Nixon v. Administrator of GSA, 433 U.S. 425 (1977), and CFTC v. Schor, No. 85-621 (July 7, 1986), do not support the constitutionality of the CICA stay provisions. As we explained in the certiorari petition (at 25-26), Nixon and Schor, unlike this case, did not involve an attempt by Congress to vest in one of its agents the authority to take action that affects the legal rights, duties and relations of government officials and private persons outside the Legislative Branch. To the contrary, the Court found it "highly relevant" in Nixon that custody of the Presidential materials was vested in Executive Branch officials (433 U.S. at 433-445), and the Court stressed that in Schor, unlike Synar, there was "no question of the aggrandizement of congressional power at the expense of a coordinate branch" (slip op. 22). Nixon and Schor involved the quite distinct question whether a duly enacted law that did not impermissibly enlarge the power of the Legislative Branch nevertheless impermissibly interfered with the internal operations of a coordinate Branch. Applying a balancing test, the Court found in each case that it did not. Nixon, 433 U.S. at 441-446; Schor, slip op. 16-23. But the Court did not suggest that a balancing approach would be proper where the very "structure of the Constitution" and its attendant "structural protections against abuse of power" are at issue, as they are with respect to the Comptroller General's functions here and in Synar (slip op. 10, 14). /2/ 5. Finally, respondents contend (Sen. & Ameron Br. in Opp. 3, 15-20; House Br. in Opp. 10-11; Comp. Gen. Br. in Opp. 11) that, irrespective of the merits, review by this Court is not warranted because there is no conflict in the lower courts on the legal questions presented. It is true that there is no conflict with respect to the precise issue of the constitutionality of the CICA stay provisions. But as we have explained (see pages 5-6, supra), the Third Circuit's decision in this case is inconsistent with the D.C. Circuit's decision in AFGE v. Pierce, which held unconstitutional a similar statutory provision that permitted an agent of Congress to lift a statutorily imposed restriction on executive action. Moreover, the CICA stay provisions are triggered with respect to several thousand government contracts each year. The question of the constitutionality of the Comptroller General's power to control the length of the stay is therefore of broad practical significance in the administration of the government procurement programs. And the possibility of a stay subject to termination only by the Comptroller General may also affect the procurement process in other cases as contracting officials seek to avoid a dispute with the Comptroller General that might delay the contract. The issue of the constitutionality of the CICA stay provisions is ripe for final resolution by this Court. That issue has been squarely joined by the Executive and Legislative Branches: the President formally took the position that the CICA stay provisions are unconstitutional when he signed the Deficit Reduction Act; the Attorney General rendered an opinion to the same effect and formally notified Congress that the Department of Justice would not defend the constitutionality of the provisions because they violate the separation of powers; and the Director of the Office of Management and Budget issued a formal, Executive Branch-wide directive that contracting should proceed as if the CICA stay provisions were not in effect (although contracting agencies were instructed to cooperate with the Comptroller General's investigation of bid protests). See Pet. 5-6. The Senate and House of Representatives in turn intervened in this suit, formally taking the position that the CICA stay provisions are constitutional and seeking to require adherence to the stay provisions on a government-wide basis. Pet. 8; Pet. App. 146a, 149a-150a. And the district court in fact entered broad injunctive relief, which respondents defended on appeal. See Sen. & Ameron C.A. Br. 57-59; see also House C.A. Br. 48-60. Although the court of appeals concluded that the injunctive relief should be limited to respondent Ameron, the Executive Branch has maintained the status quo nationwide pending the Court's disposition of this case. See Pet. 6, 8, 13 n.7. In short, this case has at all times been the focal point of litigation on the constitutional questions raised by CICA. Those questions are purely legal and will not be illuminated by litigation in other factual contexts in the lower courts. And the questions are of course ones with which this Court has particular familiarity in view of its recent decisions in Chadha and Synar. For the foregoing reasons and the reasons stated in the petition, it is respectfully submitted that the petition for a writ of certiorari should be granted. CHARLES FRIED Solicitor General OCTOBER 1987 /1/ Contrary to respondents' contention (Sen. & Ameron Br. in Opp. 14; Comp. Gen. Br. in Opp. 9), the fact that the executive agency may proceed with the contract if it makes a finding of exigent circumstances (see 31 U.S.C. (Supp. III) 3553(c) and (d)) does not undermine the conclusion that the Comptroller General retains "ultimate authority" over the timing of the contract when the agency cannot make such a finding. /2/ The House of Representatives errs in suggesting (Br. in Opp. 2-3 & n.2, 4, 11, 15) that the CICA stay provisions at issue here amount to little more than a continuation of the regime established by pre-CICA regulations. For example, in quoting an earlier GAO regulation that was reproduced in Merriam v. Kunzig, 476 F.2d 1233 (3d Cir.), cert. denied, 414 U.S. 911 (1973) (see House Br. in Opp. 2 n.2), the House conspicuously omits the concluding portion of the regulation, which made clear that a contract could be awarded after a protest was lodged if the contracting agency furnished GAO with a statement of the factors that would not permit delay until GAO ruled (476 F.2d at 1236 n.1). In Robert E. Derektor of Rhode Island, Inc. v. Goldschmidt, 506 F. Supp. 1059, 1061-1062 (D.R.I. 1980), upon which the House also relies (Br. in Opp. 2 n.2), the court appeared to acknowledge (506 F. Supp. at 1062) that the 1980 version of the Executive Branch's pre-CICA procurement regulations did not require the contracting agency to wait for the views of GAO before proceeding with the contract. See 41 C.F.R. 1-2.407-8(b)(3) (1979). Similarly, the 1984 version of the pre-CICA procurement regulations, in a passage omitted from the House's discussion (see Br. in Opp. 2-3 n.2), expressly provided that the "award need not be withheld pending final disposition by the GAO of a protest," although it provided that notice of intent to proceed "shall" be furnished to GAO and GAO's advice concerning the status of the case "should" be obtained before the award was made. See 48 C.F.R. 14.407-8(b)(3), as added, 48 Fed. Reg. 42184 (1983). See also 48 C.F.R. 14.407-8(b)(4), as added, 48 Fed. Reg. 42184 (1983) (more lenient standards for proceeding despite a protest).