Andrus v. Sierra Club
In Andrus v. Sierra Club, U.S. 99 S.Ct. 2335, 60 L.Ed.2d 943 (1979), the Supreme Court considered "whether 102(2)(C) of the National Environmental Policy Act of 1969 . . . requires federal agencies to prepare environmental impact statements . . . to accompany appropriation requests." Id. at 99 S.Ct. at 2336.
The Court concluded "that appropriation requests constitute neither 'proposals for legislation' nor 'proposals for . . . major Federal actions,' and that therefore the procedural requirements of 102(2)(C) have no application to such requests." Id. at 99 S.Ct. at 2345.