general knowledge that a particular freeway project was being planned or a general intention to advance the freeway system as a whole was insufficient to support ratification by appropriation). This is especially true where there is a pre-existing law that determines the scope of an agency’s authority, such as the FDCA. While appropriations are “Acts of Congress” that may change the existing law, there is a strong presumption that they do not. See TVA v. Hill, 437 U.S. 153, 190, 98 S.Ct. 2279, 57 L.Ed.2d 117 (1978). This is not to say that an appropriation may not constitute a ratification or change in an agency’s authority, only that an appropriation does not automatically translate to authorization. See, e.g., Brooks v. Dewar, 313 U.S. 354, 361, 61 S.Ct. 979, 85 L.Ed. 1399 (1941) (<HOLDING>). An appropriation, however, must “plainly show
holding that the proceeds of a liability insurance policy were not property of the estate holding that repeated appropriations of the proceeds of certain fees constituted a ratification of agency policy holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate recognizing a subsequent agency action as a valid ratification and indicating that the court will not substitute our judgment for that of the agency holding that the action on the part of the corporation in making payments for so long a period without objection constituted a ratification of the agreement by the corporation