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Despite holding explicit legal authority under the Impoundment Control Act to sue in federal court and compel the release of withheld funds, the Comptroller General has never exercised that power to completion against a sitting administration — including after issuing multiple adverse rulings.
Withheld billions across housing, agriculture, and environmental programs. Triggered the ICA.
Limited deferrals consistent with ICA framework; generally complied with congressional overrides.
Used deferrals extensively for domestic programs; several ruled unlawful by GAO.
Line Item Veto Act (1996) struck down by Supreme Court; limited impoundment disputes under ICA.
Withheld $214M in Ukraine military aid; GAO ruled it an ICA violation. No civil suit filed.
Pattern of withholding and redirecting appropriated funds across multiple agencies. Multiple GAO adverse rulings. No civil suits filed.