Nixon's impoundment and the 1974 Impoundment Control Act
Richard Nixon refused to spend roughly $12–18 billion in congressionally appropriated funds he disagreed with, including water projects and social programs. Congress responded with the 1974 Impoundment Control Act, which requires the president to spend appropriated funds unless Congress approves a rescission.
The law forced Nixon's successor Gerald Ford to release most impounded funds.
It created the legal presumption that appropriated money must be spent, and modern disputes over withheld funds often turn on it.
Padilla and Morelle's demand rests on that same principle — that DHS must spend the $39.6M Congress directed — making this a modern test of a 50-year-old law.
