Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
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| Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. | ||||||||||||||
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| Argued February 29, 1984 Decided June 25, 1984 |
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| Holding | ||||||||||||||
| Courts must defer to administrative agency interpretations of the authority granted to them by Congress (1) where the grant of authority was ambiguous and (2) where the interpretation was reasonable or permissible. | ||||||||||||||
| Court membership | ||||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Jr., Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor |
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| Case opinions | ||||||||||||||
| Majority by: Stevens Joined by: Burger, White, Brennan, Powell, Blackmun Marshall, Rehnquist, and O'Connor took no part in the consideration or decision of the case. |
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| Laws applied | ||||||||||||||
| Clean Air Act Amendments of 1977, Pub. L. No. 95-95, 91 Stat. 685; 40 C.F.R. 51.18(j)(1)(i)-(ii) (1983) | ||||||||||||||
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)[1], was a case in which the United States Supreme Court set forth the legal analysis for determining whether to grant deference to a government agency's interpretation of its own statutory mandate. Chevron is the Court's clearest articulation of the doctrine of "administrative deference," to the point that the Court itself has used the phrase "Chevron deference" in more recent cases.[2]
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[edit] Background
Under the Supreme Court's ruling in Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803), United States federal courts have the authority to judicially review the statutes enacted by Congress, and declare a statute invalid if it violates the Constitution. But the Constitution sets no express limits on how much federal authority can be delegated to a government agency. Rather, limits on the authority granted to a federal agency occur within the statutes enacted by Congress.
[edit] Facts
Congress amended the Clean Air Act in 1977 to address states that had failed to attain the air quality standards established by the Environmental Protection Agency (EPA) (Defendant). "The amended Clean Air Act required these 'nonattainment' States to establish a permit program regulating 'new or modified major stationary sources' of air pollution." 467 U.S. at 840. During the Carter administration, the EPA defined a source as any device in a plant that produced pollution. In 1981, after Ronald Reagan's election, the EPA adopted a new definition that allowed an existing plant to get permits for new equipment that did not meet standards as long as the total emissions from the plant itself did not increase. The Natural Resources Defense Council (NRDC), an environmental protection group, challenged the EPA regulation in federal court. Chevron, an affected party, appealed the lower court's decision.
[edit] Issue
The issue facing the Chevron court, therefore, was what standard of review should be applied by a court to a government agency's own reading of a statute that gives that agency its authority to act.
[edit] Holding
The Court, in an opinion by Justice John Paul Stevens, upheld the EPA's interpretation. A two-part analysis was born from the Chevron decision (called the "Chevron two-step test"), where a reviewing court determines:
(1) Whether the statute is ambiguous or there is a gap that Congress intended the agency to fill.
(2) If so, whether the agency's interpretation of a statute is reasonable or permissible. If an agency's interpretation is reasonable, then the court will defer to the agency's reading of the statute.
[edit] Importance
Chevron is probably the most frequently cited case in American administrative law, though some scholars suggest that the decision has had little impact on the Supreme Court jurisprudence.[3] An October 2007 citation check on the LexisNexis Shepard's citation service revealed that Chevron has been cited over 16,260 times in court opinions, law review articles, and other secondary sources.
Note that three recent decisions of the Supreme Court may limit the scope of administrative agency actions that receive Chevron deference to agency decisions that have the "force of law."[4] This new doctrine is sometimes referred to as "Chevron step zero."[5] Thus, for example, an agency that uses the formal "notice and comment" provisions of ยง 553 of the Administrative Procedure Act would be likely to receive Chevron deference, while an informal letter sent by an agency, such as an SEC "no-action" letter, would not.[6]. However, an agency action that does not receive Chevron deference may still receive deference under the old standard of Skidmore v. Swift & Co., 323 U.S. 134 (1944).[7]
[edit] See also
- List of United States Supreme Court cases, volume 467
- Chevron Corporation - the defendant
- Natural Resources Defense Council - the plaintiff
- Wednesbury unreasonableness - a similar UK doctrine
[edit] References
- ^
- ^ United States v. Mead Corp., 533 U.S. 218, 226 (2001).
- ^ Thomas W. Merrill, Judicial Deference to Executive Precedent, 101 Yale L.J. 969, 982-985 (1992)
- ^ See Barnhart v. Walton, 535 U.S. 212 (2002) United States v. Mead Corp., 533 U.S. 218 (2001); Christensen v. Harris County, 529 U.S. 576 (1999).
- ^ See, for example, Cass R. Sunstein, "Chevron Step Zero," 92 Va. L. Rev. 187 (2006).
- ^ Cf. Christensen v. Harris County, 529 U.S. 576 (1999) (no Chevron deference to opinion letter sent by NLRB about interpretation of overtime laws)
- ^ See Barnhart v. Walton, 535 U.S. 212 (2002) (stating explicitly that Skidmore still applies to agency actions that do not receive Chevron deference)
