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Supreme Court Halts 40 Years of Deference to Administrative Agencies

July 02, 2024
Client Alert

The U.S. Supreme Court on June 28 vacated and remanded two circuit court rulings, ending the Chevron doctrine, the decades-old judicial framework that mandated judicial deference to an executive branch agency’s interpretation of the federal statutes that it administers.1 In a 6-3 decision in Loper Bright Enterprises v. Raimondo, Chief Justice John Roberts delivered the majority opinion that overruled the Chevron doctrine because it violated the Administrative Procedure Act of 1946 (APA) and the constitutional separation of powers.

History of Chevron Doctrine and Agency Deference

The court’s decision in Chevron U.S.A. v. Natural Resources Defense Council2 created the two-step judicial framework that courts were required to use when interpreting statutes administered by federal agencies. The Chevron doctrine’s first step required courts to determine whether Congress directly spoke on the issue. If so, that ended the inquiry. If not, the second step required a reviewing court to defer to the agency’s permissible interpretation of the statute.3 Thus, when Congress was silent, or a statutory provision was ambiguous and the agency offered a permissible interpretation, the court was required to afford deference to the  agency’s interpretation.

Read the full article here.

1 Loper Bright Enterprises v. Raimondo, 603 U.S. [ ] (2024) (consolidated with Relentless v. Department of Commerce).

2 Chevron U.S.A. v. Natural Resources Defense Council, 467 U.S. 837 (1984).

3 Chevron, at 843.

Information contained in this publication should not be construed as legal advice or opinion or as a substitute for the advice of counsel. The articles by these authors may have first appeared in other publications. The content provided is for educational and informational purposes for the use of clients and others who may be interested in the subject matter. We recommend that readers seek specific advice from counsel about particular matters of interest.

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