express procedures, such procedures must be strictly observed. Two such provisions are bicameralism and presentment in the enactment of law. (6) The presentment process—especially the President's veto power—was intended by the Framers to provide a mechanism by which the executive branch could defend itself against legislative encroachment and could prevent ill-conceived policies. (7) Similarly, the bicameralism requirement was formulated in order to hinder congressional action and thereby prevent legislative encroachment. (8) The action of the House of Representatives is legislative in nature because (a) it modifies rights and duties of individuals outside the legislative branch; (b) the enactment would otherwise have required a private law, which is a legislative function; and (c) the nature of the action is inherently legislative. (9) When the Framers intended to authorize Congress to exercise power outside of the bicameral and presentment principles, it provided alternate procedures explicitly; other procedures cannot be admitted. (10) Because the action of the House of Representatives was legislative, but did not conform to the mode of action specifically stated by the Constitution for legislative action, it is therefore invalid, unenforceable, and not binding. Concurrence Justice Powell, in a concurring opinion, argued that to invalidate all legislative veto provisions is a serious matter, as Congress views the legislative veto as essential to controlling the executive branch, and should therefore be undertaken with caution. However, Congress's action in this case is nonetheless unconstitutional. Contrary to the views of the majority, Congress's action is not legislative in character but adjudicative, and it therefore violates the principle (called the anti-aggrandizement principle) that Congress may not expand its own power into the areas of competence of the other branches. The Constitution specifically attempted to prevent this form of aggrandizement in the Bill of Attainder Clause, Art. I, § 9, cl. 3, which prohibits Congress from undertaking legislative trials that lack the safeguards and accountability of judicial trials. For a house of Congress to force the deportation of Chadha would amount to such a legislative trial. Dissents Justice White, dissenting, argued that (1) the legislative veto power is absolutely necessary to modern government, as exemplified by the legislative veto powers granted in the War Powers Act of 1973. (2) The absence of constitutional provisions for alternate methods of action does not imply their prohibition by the Constitution, and the court has consistently read the Constitution to respond to contemporary needs with flexibility. (3) The legislative