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Bowsher V. Senar, 1986 Essay title: Bowsher V. Senar, 1986 Bowsher v. Senar, 1986 In order to eliminate the federal budget deficit, Congress enacted the Balanced Budget and Emergency Deficit Control Act of 1985 (Act), popularly known as the “Gramm-Rudman-Hollings Act,” which sets a maximum deficit amount for federal spending for each of the fiscal.