## Facts

- The Secretary of Agriculture issued milk marketing orders under the Agricultural Marketing Agreement Act of 1937 (AMAA) setting minimum prices handlers must pay producers based on milk classifications.
- The orders treated “reconstituted milk” (dry milk powder mixed with water) as Class II milk and imposed a “compensatory payment” when reconstituted milk was not used for surplus products, equal to the difference between Class I and Class II prices.
- Individual dairy consumers and a nonprofit organization alleged the compensatory payment made reconstituted milk uneconomical for handlers, limiting availability of lower-priced fluid milk products.
- The District Court dismissed the consumers’ and nonprofit’s challenge, concluding the AMAA’s structure barred them from judicial review.
- The D.C. Circuit held the consumers had standing and that the AMAA did not show clear congressional intent to foreclose consumer suits.
- The Supreme Court granted certiorari to decide whether consumers may obtain judicial review of these marketing orders.

## Issues

1. Whether the AMAA’s statutory scheme implicitly precludes ultimate consumers of dairy products from obtaining judicial review of milk marketing orders.
2. Whether the presumption favoring judicial review is overcome where Congress provides a detailed administrative and judicial review path for handlers but not consumers.

## Decision

- The Supreme Court reversed the D.C. Circuit and held that individual consumers may not obtain judicial review of the challenged milk marketing orders.
- The Court found Congress’s intent to limit review was fairly discernible from the AMAA’s structure, which provides handlers a specific administrative process and route to judicial review while providing no comparable role for consumers.
- The Court reasoned that permitting consumer suits would disrupt the AMAA’s coordinated regulatory process and could allow handlers to bypass exhaustion requirements by proceeding through consumer plaintiffs.
- The decision was unanimous.

## Legal Principles

- Statutory preclusion of judicial review may be inferred from the statute’s structure, legislative history, and the nature of the administrative action, not solely from express “no review” language.
- The presumption favoring judicial review is rebutted when congressional intent to preclude review is fairly discernible from a comprehensive remedial scheme.
- When Congress creates a specific process for a defined class (here, handlers) to object, obtain hearings, exhaust administrative remedies, and then seek judicial review, courts may treat that structure as excluding other classes (here, consumers) from review.
- The question may be one of who may obtain review under the statute, even if plaintiffs could otherwise satisfy injury and zone-of-interests analyses.

## Conclusion

The Court held that the AMAA’s detailed, handler-centered objection and review mechanism implicitly bars suits by ultimate consumers challenging milk marketing orders, limiting judicial review largely to the regulated handlers within the statute’s prescribed process.


Block v. Cmty. Nutrition Inst., 467 U.S. 340 (1984)