McLaughlin Chiropractic Associates, Inc. v. McKesson Corp.

Majority reasoning

The majority held that the default rule in administrative law — backed by the text of the Administrative Procedure Act (a law governing how courts review agency decisions) — is that parties in civil enforcement proceedings may challenge an agency's interpretation of a statute, and district courts may independently decide whether that interpretation is correct. The Court reasoned that the Hobbs Act's grant of "exclusive jurisdiction" to courts of appeals to "determine the validity" of agency orders refers specifically to entering a declaratory judgment (a formal court ruling declaring something valid or invalid) in a pre-enforcement proceeding, not to the general process of interpreting a statute in a later lawsuit. Because the Hobbs Act — unlike the Clean Water Act, CERCLA, and the Clean Air Act — does not contain language expressly barring district courts from reviewing agency interpretations in enforcement proceedings, the default rule applies and district court review is available. The majority also distinguished the key precedent relied on by the other side, Yakus v. United States, noting that the wartime law in that case contained a second, explicit sentence barring all other courts from even "considering" the validity of covered regulations — language that Congress deliberately chose not to include when it enacted the Hobbs Act six years later. Finally, the majority rejected the practical concern that allowing district courts to disagree with agencies would create chaos, noting that circuit splits are a normal part of the legal system and that requiring all potentially affected parties to file pre-enforcement challenges within 60 days or forever lose their right to contest an agency's interpretation would be impractical and unfair.

Dissent reasoning

The dissent argued that the Hobbs Act's plain text already answers the question: by giving courts of appeals "exclusive jurisdiction" to "determine the validity" of covered agency orders, the Act necessarily strips district courts of any power to make that same determination in a later lawsuit. Justice Kagan wrote that when a party in a district court asks that court to disregard an agency order because it misreads a statute, the party is asking the court to "determine" whether the order is "valid" — exactly what the Hobbs Act reserves for courts of appeals alone. The dissent contended that the majority's reading improperly narrows the phrase "determine the validity" by silently inserting the words "issue a declaratory judgment" — a form of adding words Congress did not write. The dissent also argued that prior Supreme Court decisions, including Yakus and Port of Boston Marine Terminal Assn. v. Rederiaktiebolaget Transatlantic, already held that Hobbs Act-type statutes prevent exactly this kind of later, collateral challenge to agency action in district court, and that the majority's attempt to limit those cases to narrow estoppel principles misreads their holdings. Finally, the dissent warned that the majority's ruling undermines the Hobbs Act's core purpose — providing quick, final resolution of challenges to agency rules — by allowing any party, at any point in the future, to relitigate the validity of even well-settled agency orders, and by letting regulated parties ignore agency rules and wait to contest them only if an enforcement action is ever brought.