TVA v. Hill: TVA found an endangered species of fish while constructing a dam. The Endangered Species Act required TVA to stop construction. TVA argued that continued congressional appropriations after determination implied repeal of that portion of the ESA. - Rule: The doctrine of disfavoring repeals by implication is even stronger when the repeal rests solely on an Appropriations Act. o Concern that Riders will pass without real consideration by Congress since members are right to presume that funds will be used for lawful purposes.