## Facts

- The Forest and Rangeland Renewable Resources Planning Act of 1974 (RPA) required the Secretary of Agriculture to prepare a Renewable Resource Assessment and a Renewable Resource Program recommending Forest Service program levels and funding.
- For fiscal year 1979, the President’s budget proposed funding for Forest Service programs below levels recommended in the RPA Program.
- RPA § 1606(b) required the President to provide Congress an explanation when the annual budget recommendations diverged from the RPA Program’s recommended levels.
- National Wildlife Federation (NWF) asserted the submitted explanation was insufficiently detailed and sought to compel more extensive explanatory material from the President and the Office of Management and Budget (OMB).

## Issues

1. Whether a federal court may grant mandamus or declaratory relief compelling the President (and OMB) to provide a more detailed budget explanation under 16 U.S.C. § 1606(b).
2. Whether the explanation submitted with the fiscal year 1979 budget was so inadequate under § 1606(b) that judicial relief was warranted.
3. Whether mandamus was available given the discretionary, policy-laden character of presidential budget decisions and explanatory statements.

## Decision

- The D.C. Circuit affirmed the district court’s dismissal of NWF’s suit.
- The court held that mandamus and declaratory relief were inappropriate mechanisms to police the sufficiency of the President’s § 1606(b) explanation.
- The court concluded that the submitted materials satisfied the statute at least to the extent courts could properly enforce it, and that disputes over explanatory detail were for the political branches.

## Legal Principles

- Mandamus is an extraordinary remedy available only to compel a clear, ministerial, nondiscretionary duty; it is not used to supervise discretionary executive judgments intertwined with policy choices.
- Statutory requirements that the President submit explanations accompanying budget proposals, where the adequacy of explanation is not judicially measurable by clear standards, are generally unsuitable for judicial enforcement against the President or close presidential advisors.
- Declaratory relief cannot be used to achieve indirectly what mandamus cannot accomplish directly when the practical effect would be to direct how the President and OMB prepare and present budget justifications.
- Where Congress structures reporting and explanation duties as part of interbranch budget oversight, enforcement is primarily through legislative tools (e.g., oversight and appropriations), not judicial orders evaluating policy justifications.

## Conclusion

The D.C. Circuit declined to compel the President or OMB to provide a more detailed RPA budget explanation, holding that mandamus and declaratory judgment were improper given the discretionary, political nature of budget justifications and the separation-of-powers concerns implicated by judicial supervision of such explanations.


Nat'l Wildlife Fed'n v. United States, 626 F.2d 917 (D.C. Cir. 1980)