U.S. Supreme Court Overrules Chevron Deference in Landmark Ruling

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In a landmark decision that marks a significant shift in administrative law, the U.S. Supreme Court has abolished the Chevron deference doctrine, which has guided judicial review of administrative agency actions for the past four decades. This decision was delivered in the cases of *Loper Bright Enterprises v. Raimondo*, consolidated with *Relentless Inc. v. U.S. Department of Commerce*.

The Chevron deference doctrine, first articulated in the Supreme Court’s 1984 ruling in *Chevron U.S.A. Inc. v. Natural Resources Defense Council*, has been a cornerstone of administrative law. Under this doctrine, courts were instructed to follow a two-step process when evaluating the legality of agency regulations and decisions. First, they assessed whether the statutory language was clear on the issue in question. If the statute was deemed clear, the inquiry would end there. If the statute was ambiguous, courts would then defer to the agency’s interpretation if it was found to be reasonable.

Over the years, Chevron deference was cited in over 18,000 court decisions and examined in more than 22,000 academic and legal publications. Despite its widespread application, the doctrine faced growing criticism for creating significant challenges for plaintiffs challenging agency actions and allowing substantial policy shifts between different presidential administrations. The need to continuously refine the application of Chevron, as noted by Chief Justice John Roberts, led to what he described as a “dizzying breakdance” of judicial interpretation.

Supreme Court’s Ruling: Chevron Overruled

On a 6-3 vote, the Supreme Court overturned the Chevron doctrine, ruling that courts must now exercise independent judgment to resolve all relevant legal questions, including those involving complex or technical statutes. This decision marks a departure from the practice of deferring to an agency’s interpretation of ambiguous statutes. Instead, courts are now required to determine the “single, best meaning” of the statutory text without simply deferring to the agency’s view.

The case in question involved a rule by the National Marine Fisheries Service (NMFS) under the Magnuson-Stevens Act (MSA), which mandated that Atlantic herring fishermen cover the costs of third-party observers to collect data for government use. Although the MSA permits NMFS to impose such costs in specific circumstances, it does not explicitly address the Atlantic herring fishing industry. Vessel owners challenged this rule, leading to appeals in both the District of Columbia and the 1st U.S. Circuit Court of Appeals. Both courts upheld NMFS’s rule based on Chevron deference, with one court interpreting the lack of clear statutory direction as an ambiguity and accepting NMFS’s resolution of it, while the other court confirmed NMFS’s authority without detailing its Chevron application.

The Court’s Analysis

Chief Justice Roberts, writing for the majority, argued that Chevron deference had no foundation in the Court’s prior administrative law precedents. He pointed out that before Chevron, the Court had consistently adhered to its constitutional obligation under Article III to “say what the law is.” The doctrine of Chevron, he noted, was not present in pre-New Deal administrative cases and did not align with the principles codified in the Administrative Procedure Act (APA). Specifically, APA Section 706 mandates that reviewing courts decide all relevant legal questions and interpret statutory provisions.

Although the Supreme Court’s decision in *Loper Bright* explicitly overturns Chevron, the Court clarified that this ruling does not retroactively impact previous cases decided under Chevron. The principle of statutory stare decisis—respect for previous judicial interpretations of statutes—remains strong, as Congress can amend statutes if it disagrees with the Court’s interpretations.

### Future Implications for Agency Policymaking

The abolition of Chevron is not expected to drastically alter existing regulatory frameworks immediately. However, the decision emphasizes that federal agencies must exercise caution when interpreting statutes and avoid expansive interpretations without clear congressional authorization. This follows a similar warning issued in *West Virginia v. EPA*, where the Supreme Court had vacated the EPA’s Clean Power Plan for overstepping its regulatory authority.

The *Loper Bright* decision may significantly impact litigation involving various Biden administration actions, particularly those related to climate change, such as the Securities and Exchange Commission’s climate disclosure rules, or controversial measures like student loan debt cancellations. Such actions may face increased scrutiny under the new standard, which requires a closer alignment with the “best reading” of the relevant statutes.

Additionally, the Supreme Court’s recent decision in *Corner Post Inc. v. Federal Reserve* further impacts administrative law by clarifying that for the purposes of the general statute of limitations under 28 U.S.C. § 2401, an APA claim accrues not when the action is finalized but when it causes harm to an individual.

As the legal community adjusts to this significant change, it remains to be seen how agencies and litigants will navigate the post-Chevron landscape. The ruling underscores the need for rigorous statutory interpretation and careful consideration of agency actions within the bounds of congressional intent and constitutional limits.