Bill would void decades of federal safety rules and let citizens sue to block enforcement

What it does

This bill would prohibit Congress from delegating legislative power to executive agencies, and would void all existing rules, regulations, and agency decisions that the bill deems to be unconstitutional delegations. It requires the Comptroller General to report on which statutes contain such delegations within 6 months, and creates a private right of action allowing citizens to sue to block enforcement of any agency rule or regulation deemed non-compliant. The bill would effectively invalidate decades of administrative law and agency rulemaking.

Why we flagged it

The bill's stated purpose is constitutional restoration, but its operative mechanism—voiding all agency rules deemed to contain 'delegated legislative power' and creating a private right of action to challenge them—would function as a sweeping deregulation of the administrative state. The definition of 'delegation' is so expansive it would capture routine agency rulemaking upheld by courts for over a century.

What the text implies

• The bill's 90-day grace period before enforcement begins creates a window in which regulated entities and ideological plaintiffs can prepare litigation to challenge existing rules, potentially paralyzing enforcement during that period.
• The 'de novo' standard of review (subsection 152(c)) strips courts of deference to agency expertise and forces judges to re-examine every factual and legal judgment underlying a rule—a standard that would make agency action nearly impossible to defend.
• The definition of 'delegation' excludes only 'factual findings' but the bill's language ('creation or clarification of any regulation...not fully and completely defined') would likely void statutes that authorize agencies to set safety thresholds, emission limits, or benefit eligibility based on evolving science.
• Private citizens gain standing to sue the United States for injunctive relief against any rule they deem non-compliant, creating a litigation pathway for regulated industries to block enforcement without waiting for formal rulemaking or judicial review.
• The bill does not grandfather existing rules or provide a transition mechanism; it would render void on its effective date all agency regulations, creating immediate legal uncertainty for every regulated entity and every citizen relying on those protections.

Section numbers refer to the bill text the analysis read — linked under Primary records below.

Who it affects

While the bill frames itself as restoring constitutional separation of powers, its practical effect would be to paralyze federal regulation across health, safety, environment, labor, and consumer protection. Citizens would lose access to agency protections (FDA drug approval, EPA pollution limits, OSHA workplace safety, SEC fraud enforcement) that depend on agency discretion to adapt rules to new circumstances. The bill's definition of 'delegation' is so broad it would void statutes that merely

Who stands to gain

• regulated industries (pharmaceuticals, energy, finance, manufacturing) seeking to block or delay saf
• litigation funders and law firms specializing in administrative law challenges
• entities subject to EPA, FDA, OSHA, SEC, FTC, and other agency enforcement

Named in the bill

Congress, Comptroller General of the United States, Executive Branch, Administrative agencies (EPA, FDA, OSHA, SEC, FTC, etc.), Interstate Commerce Commission, Supreme Court, Federal courts

Where it stands

• Jan 9, 2025 — Introduced · Congress.gov: “Introduced in Senate”
• Jan 9, 2025 — Referred to Senate Committee on Homeland Security and Governmental Affairs · Congress.gov: “Read twice and referred to the Committee on Homeland Security and Governmental Affairs”

Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.