William C. Dart sought to overturn a decision by the Secretary of Commerce imposing civil sanctions for violations of the Export Administration Act. The Export Act precludes judicial review of such fines under its so-called “finality clause.”

What are the competing concerns of the person fined and the limited appeal procedure provided in the Export Act? Has the world changed in a way that has changed the balance between these concerns?

Dart v. United States, 848 F.2d 217 (D.C.

Cir. 1988).