In a landmark ruling today, the United States Supreme Court overturned Chevron v. Natural Resources Defense Council, which for 40 years has required federal courts to defer to an agency’s reasonable interpretation of its enabling statutes. This long-anticipated decision, handed down through Loper Bright Enterprises v. Raimondo, catches no one by surprise; the doctrine has been watered down with exception after exception over the last few decades, and its demise seemed imminent with the court’s current composition. But the ruling is no less monumental.
Over the dissent of three justices, the majority ruled that Chevron is inconsistent with the Administrative Procedures Act’s mandate that the judiciary is to exercise its own judgment regarding questions of statutory law, and the doctrine improperly relies on a false presumption that Congress intends the ambiguities in a statute to vest the agency with discretion in determining the scope of its own jurisdiction and interpretation of the statute.
The ramifications of this decision will be felt in every corner of the administrative world. An untold number of federal judicial rulings hinged on Chevron deference to the agency’s interpretation over the last four decades. There is no telling which statutory interpretations will now be overturned, since each time the federal judiciary relied on Chevron, it inherently failed to exercise its own judgment as to what the statute means. In some instances, the court’s interpretation may ultimately align with the agency’s, in others it will not. The time is ripe to find out.
For questions on today’s ruling, or for any litigation, appeals or environmental matters, please contact Gaëtan Gerville-Réache or your Warner attorney.
