Docket 22-451
Loper Bright Enterprises v. Raimondo
DecidedJun 28, 2024
6-3decision
Source: CourtListener.
Supreme Court ends requirement that courts defer to agency interpretations of ambiguous laws
What it does
The ruling overturns the 1984 Chevron doctrine, which required courts to accept an agency's "permissible" reading of an ambiguous law even if the court thought a different reading was better. Going forward, courts must independently interpret statutes using traditional legal tools, though they may still consider an agency's expertise as persuasive (but not binding) evidence, under the older Skidmore standard.
Who benefits
Businesses, individuals, and other parties who challenge federal agency rules in court now have a better chance of winning, since judges will no longer be required to side with the agency's reading of an ambiguous statute.
Who is affected
Federal agencies such as the EPA, FDA, NMFS, and others that regulate industries under ambiguous statutory language will find it harder to have their interpretations automatically upheld in court; agencies must now win on the merits of the statute's best reading rather than on reasonableness alone.
Practical impact
Federal courts reviewing challenges to agency rules and interpretations will no longer automatically uphold an agency's reading of an ambiguous statute just because it is reasonable; they must independently determine the best reading of the law, giving only persuasive weight to agency views. This is expected to make it easier for regulated parties to successfully challenge agency rules in areas like environmental regulation, healthcare, financial regulation, and immigration, while agencies will need to rely more on clear, specific statutory delegations to defend their regulatory authority.
Majority reasoning
Chief Justice Roberts wrote that Article III gives courts, not agencies, the job of saying what the law means, tracing this back to Marbury v. Madison and the Framers' vision of independent judicial judgment. The Administrative Procedure Act's Section 706 directs "the reviewing court" — not the agency — to decide "all relevant questions of law" and interpret statutory provisions, with no textual basis for deferring simply because a law is ambiguous. The majority reasoned that Chevron's premise — that statutory ambiguity signals an implicit congressional delegation to the agency — is a fiction, since ambiguities are often just accidents of imprecise drafting rather than deliberate delegations, and agencies have no special competence over courts in resolving legal ambiguities. On stare decisis, the majority concluded Chevron was poorly reasoned, unworkable due to the elusive concept of "ambiguity," and had not fostered reliable reliance since the Court itself stopped applying it after 2016, so past cases that specifically upheld agency actions under Chevron remain undisturbed but the framework itself is overruled.
Dissent reasoning
Justice Kagan, joined by Justice Sotomayor and (in part) Justice Jackson, argued that Chevron correctly recognized that regulatory statutes inevitably contain gaps and ambiguities that someone must fill, and that Congress would generally prefer the expert, politically accountable agency to make that call rather than unelected judges. The dissent contended that Section 706 of the APA is genuinely silent on the standard of review for legal questions and is compatible with deference, pointing to 1940s cases like Gray v. Powell and NLRB v. Hearst Publications where the Court deferred to agency interpretations shortly after the APA's passage. The dissent argued Chevron deserved heightened stare decisis protection because Congress could have overridden it but never did in 40 years, and because thousands of lower court decisions and agency rules have relied on it, warning that overruling Chevron represents the Court seizing for itself decision-making authority over technical and policy-laden questions that properly belongs to expert agencies accountable to the President.
Constitutional question
Whether courts must defer to a federal agency's reasonable interpretation of an ambiguous statute it administers, or whether courts must instead use their own independent judgment to determine the statute's best meaning.
Precedent changed
Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. (1984) is explicitly overruled, though the Court held that specific past decisions applying Chevron to uphold particular agency actions remain subject to ordinary statutory stare decisis and are not automatically undone.