Supreme Court Overrules Chevron Doctrine, Weakens the Power of Federal Agencies to Interpret Statutes

​​Last week, the U.S. Supreme Court overturned the historic Chevron doctrine, which required federal courts to defer to administrative agencies’ reasonable interpretations of ambiguous or broad statutes. In Loper Bright Enterprises v. Raimondo and Relentless v. Department of Commerce, the Supreme Court rejected this doctrine. The Court focused on the interpretative role of the judiciary. It concluded that Chevron was inconsistent with the Administrative Procedure Act, which requires courts to review agency actions and “decide all relevant questions of law.”
 
The Chevron doctrine guided administrative law decisions for 40 years. It essentially empowered agencies to interpret ambiguous terms in federal statutes, relying on their unique expertise. Under Loper Bright and Relentless, courts are now the ultimate decision makers as to what a statutory term means. They need not defer to agency interpretations—although the agency’s view will be considered, among other statutory interpretation tools such as legislative intent.
 
Under Chevron, courts could overturn agency interpretations of statutory language, but the bar was high. Courts interpreting agency rules or adjudications now “must exercise their independent judgment in deciding whether an agency has acted within its statutory authority.” This is true even with respect to technical matters. However, the Court did not overrule previously decided cases in which a court relied on Chevron to uphold an agency action.
 
In some cases in which SCI has been involved, most notably those involving gray wolves, the court rejected the agency’s interpretation of a statute, even under Chevron’s deferential standard. And going forward, a court’s role is to find the “best” interpretation of a statutory term. One would hope that, in most cases, the agency interpretation is the “best” because it is consistent with the statute’s language and Congress’ intent. Where Loper Bright and Relentless will potentially have the greatest impact are situations in which the agency has adopted a novel interpretation, or changed definitions, such as after an Administration change. But one thing is certain: the Court’s decision will likely lead to many new cases challenging agency interpretations.