deportation would result in "extreme hardship". After making such a finding, the Attorney General would send a report to Congress, and either the House or Senate could veto the Attorney General's decision by majority vote. In Immigration and Naturalization Service v. Chadha, 462 U.S. 919 (1983), the Supreme Court considered such a case, in which the Attorney General had found that deporting an essentially stateless person would result in extreme hardship, and the House had vetoed the Attorney General's decision. The Court held that a legislative veto on the part of one chamber of the legislature was unconstitutional as violating both the principle of bicameralism embodied in Article I, Section 1 and Section 7, and the presentment provisions of Clauses 2 and 3 of Section 7. The Court's analysis of the presentment issue stated that a provision for a two-chamber veto, though complying with bicameralism, and a provision for veto by a Congressional committee suffer the same constitutional infirmity. In the words of dissenting Justice White, the Court in Chadha "sound[ed] the death knell for nearly 200 other statutory provisions in which Congress has reserved a 'legislative veto.'" Constitutional Convention Delegates to the Constitutional Convention of 1787 that drafted the U.S. Constitution considered and rejected proposals for a legislative veto designed to reconcile the states to the federal union. Edmund Randolph proposed that: "The National Legislature ought to be impowered [sic] . . . to negative all laws passed by the several States contravening in the opinion of the National Legislature the articles of Union." The provision became part of Alexander Hamilton's proposal for a new government based on national consolidation, all but eliminating state sovereignty. States As of 1975, 10 states' constitutions allowed the governor to reorganize state government departments subject to a legislative veto: Alaska, California, Illinois, Kansas, Maryland, Massachusetts, Michigan, Missouri, New Jersey, and Vermont. Three states had statutes authorizing this procedure: Kentucky, Pennsylvania, and South Carolina. In the case of Pennsylvania, however, the State Supreme Court has invalidated the legislative veto. See also Veto United States Constitution References Notes Bibliography Barbara Hinkson Craig, Chadha: The Story of an Epic Constitutional Struggle (NY: Oxford University Press, 1988) Michael J. Berry, The Modern Legislative Veto: Macropolitical Conflict and the Legacy of Chadha (University of Michigan Press, 2016) External links Constitution with Annotations - Article II. Legislative Department Federal government of the United States United States administrative law American