The US Supreme Court has ruled that courts must exercise independent judgment in assessing an agency’s statutory authority, effectively overturning the precedent set by Chevron U.S.A. v. Natural Resources Defense Council. This landmark ruling came from the case Loper Bright Enterprises v. Raimondo, which revolved around the National Marine Fisheries Service’s (NMFS) requirement for petitioners to bear the costs of observers mandated under a fishery management plan.
The petitioners argued that NMFS’s actions exceeded the agency’s statutory mandate under the Magnuson-Stevens Fishery Conservation and Management Act (MSA). The Supreme Court did not resolve the specific facts of Loper, but the controversy provided sufficient legislative ambiguity for the Court to overturn the Chevron doctrine.
In Chevron, the Court previously held that an agency’s interpretation of its mandate deserved deference when it involved reconciling conflicting policies. However, the current ruling concludes that Chevron deference compels judges to abdicate their statutory responsibilities. The decision included an examination of the Administrative Procedure Act (APA), which mandates that reviewing courts decide “all relevant questions of law.” Hence, deference to agency interpretations was deemed inconsistent with the APA.
The dissent highlighted the necessity of deferring to agencies due to their subject matter expertise, contrasting judges who may lack specialized knowledge. Nonetheless, the majority maintained that interpretative questions about an agency’s statutory authority remain legal questions, thereby rebutting the deference notion under the APA’s framework.
This decision does raise concerns regarding judicial continuity under the principle of stare decisis. The Court acknowledged that rectifying judicial mistakes occasionally necessitates overruling past decisions. Significantly, the majority noted that prior case holdings utilizing Chevron deference, including the original Chevron case itself, remain intact. This provision could mitigate fears of a surge in litigation revisiting settled issues.
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