Huffman v. Western Nuclear, Inc.

486 U. S. 663

June 15, 1988

The Atomic Energy Act required the Department of Energy to restrict enrichment of foreign Uranium “to the extent necessary to assure the maintenance of a viable domestic uranium industry.” By the mid-1980s, the Department of Energy determined that the domestic Uranium industry had last been viable in 1983, and that no possible restrictions could return it to viability. The Department thus refused to impose any restrictions at all. Domestic Uranium producers charged that the Department had no right to abandon all restrictions.

The Court unanimously ruled that the Department was in the clear. Blackmun emphasized that the Department had to follow a statutory command. If the Department truly felt that the domestic Uranium industry could never be made viable, then any restrictions imposed would still fail to meet the statutory standard. Thus, it was abandonment of duty to impose no restrictions at all. All in all, a very simple textualist ruling.

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