In the 1990 case Metropolitan Washington Airports Authority v. Citizens for the Abatement of Aircraft Noise, Inc., a group of citizens challenged the constitutionality of certain provisions in the Metropolitan Washington Airports Act of 1986. The act transferred control over two major airports from federal to state authorities but retained a board composed mostly of members appointed by Congress with veto power over significant decisions made by local airport authorities. The Supreme Court ruled that this arrangement violated separation-of-powers principles because it gave legislative powers to an entity under direct congressional control without presidential oversight or approval, thus bypassing normal constitutional procedures for lawmaking and execution. Therefore, these provisions were deemed unconstitutional and struck down.

In the dissenting opinion for Metropolitan Washington Airports Authority v. Citizens for the Abatement of Aircraft Noise, Inc., Justice White argued that Congress did not violate separation of powers principles by retaining a veto over actions taken by the Metropolitan Washington Airports Authority (MWAA). He contended that MWAA was essentially a federal agency and therefore subject to congressional control. The majority's view, he asserted, would unnecessarily limit Congress's ability to delegate authority while maintaining oversight. Furthermore, he disagreed with their interpretation of Chadha case precedent as prohibiting legislative vetoes in all circumstances; instead, he believed it only applied when such vetoes were used to overturn executive branch decisions or judicial rulings. In this case, since MWAA was acting as an agent of Congress rather than an independent entity or part of another branch’s functionaries according to him - its decisions could be legitimately subjected to congressional review and reversal without violating constitutional norms.