The recent U.S. Supreme Court decision in Loper Bright v. Raimondo and Relentless v. Department of Commerce has overturned the long-standing Chevron deference doctrine, marking a significant shift in how courts interpret agency actions. The Court’s new Loper Bright doctrine emphasizes the importance of independent judicial review of agencies’ statutory authority, aligning more closely with the Administrative Procedure Act’s requirements.
For over 40 years, the Chevron framework guided judicial review of agency interpretations of statutes, with courts deferring to agencies unless Congress had directly spoken to the issue at hand. However, the Court found Chevron deference incompatible with the APA and courts’ duty to interpret laws enacted by Congress. The decision to overrule Chevron was based on the view that the doctrine was fundamentally misguided and had proven unworkable, leading to ambiguity and inconsistencies in its application.
While the end of Chevron deference does not eliminate all forms of deference to agencies, it does signal a significant shift in how courts approach agency decisions. The Court’s decision emphasizes the importance of interpreting laws independently and may lead to changes in how Congress delegates authority to agencies and how agencies make decisions. While some concerns have been raised about the impact of overturning Chevron on the regulatory state, the decision is likely to reshape how statutes are written, interpreted, and enforced.
Moving forward, courts will be required to exercise independent judgment in assessing agency actions, rather than automatically deferring to agency interpretations. The decision in Loper Bright represents a significant departure from the previous Chevron doctrine and sets a new standard for judicial review of agency actions. It remains to be seen how this decision will impact future legal challenges and agency decision-making processes.
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