Independent Gasoline Marketers Council, Inc. v. Duncan; Marathon Oil Corporation v. Carter

Summary

The United States District Court for the District of Columbia held that the Petroleum Import Adjustment Program, established through presidential proclamations, exceeded the authority granted by the Trade Expansion Act and the Emergency Petroleum Allocation Act. The court also concluded that the program's gasoline conservation fee conflicted with congressional restrictions and could not be justified as an inherent presidential power. The court declared the program unlawful and enjoined its implementation.

Holdings

1. Section 232 of the Trade Expansion Act authorizes import controls, including license fees that directly affect the price or quantity of imports, but it does not authorize the President to impose a general gasoline conservation fee whose primary purpose and effect are to regulate domestically produced goods and reduce overall gasoline consumption.
2. The Emergency Petroleum Allocation Act did not provide authority for the gasoline conservation fee or entitlement mechanism because the statutory procedural requirements incorporated into the Act were not satisfied.
3. The President lacked inherent constitutional authority to impose the gasoline conservation fee where Congress had not authorized the measure and had manifested an intent to withhold such authority.

Questions Presented

1. Whether section 232 of the Trade Expansion Act authorized the President to implement the Petroleum Import Adjustment Program, including a fee whose economic burden was shifted to consumers of domestic and imported gasoline.
2. Whether the Emergency Petroleum Allocation Act authorized the program's entitlement mechanism despite the absence of the procedural safeguards incorporated from the Economic Stabilization Act and the Administrative Procedure Act.
3. Whether the President possessed inherent constitutional authority to impose a gasoline conservation fee in response to national-security and energy concerns.

Disposition

other