Chevron deference in rulemaking interpretation
Chevron Deference in Rulemaking Interpretation
What is Chevron Deference?
Chevron deference is a principle from U.S. administrative law that compels courts to defer to an administrative agency’s interpretation of a statute that it administers, so long as:
The statute is ambiguous or silent on the specific issue (Step One).
The agency’s interpretation is reasonable (Step Two).
This doctrine arises from the landmark Supreme Court case Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. (1984).
Why Chevron Deference Matters in Rulemaking
Agencies often make rules interpreting statutes they administer.
Courts acknowledge agencies’ expertise and policymaking role.
Encourages uniformity and predictability in regulatory interpretations.
Limits judicial intrusion in technical or complex policy areas.
The Two-Step Test of Chevron:
Step One: Has Congress directly spoken to the precise question? If yes, follow Congress’s intent.
Step Two: If not, is the agency’s interpretation reasonable? If yes, courts defer.
🔍 Key Cases on Chevron Deference
1. Chevron U.S.A., Inc. v. Natural Resources Defense Council (1984)
Citation: 467 U.S. 837
Facts:
EPA interpreted “stationary source” in the Clean Air Act to allow flexible pollution controls across multiple facilities.
Issue:
Was the EPA’s interpretation reasonable under the statute?
Held:
The Court introduced the two-step test and upheld EPA’s interpretation as reasonable.
Significance:
Established Chevron deference as a foundation for judicial review of agency interpretations.
Recognized agencies’ expertise in technical policy.
Marked a shift toward judicial deference.
2. United States v. Mead Corp. (2001)
Citation: 533 U.S. 218
Facts:
The U.S. Customs Service issued a classification ruling letter, which the Court reviewed.
Issue:
Does Chevron deference apply to all agency interpretations?
Held:
No. Chevron applies when Congress delegates authority to the agency and the agency acts with force of law (e.g., formal rulemaking or adjudication).
Interpretations like informal letters get Skidmore deference (based on persuasiveness).
Significance:
Limits Chevron deference to formal agency actions.
Distinguishes between rulemaking and informal guidance.
Adds nuance to agency interpretation deference.
3. National Cable & Telecommunications Association v. Brand X Internet Services (2005)
Citation: 545 U.S. 967
Facts:
FCC reclassified cable broadband providers under a different statutory provision than courts had previously interpreted.
Issue:
Could the FCC change its interpretation and receive Chevron deference?
Held:
Yes. The Court upheld the FCC’s new interpretation as reasonable and entitled to Chevron deference, even if it conflicted with prior judicial interpretation.
Significance:
Agencies can change interpretations with reasoned explanation.
Courts defer to agencies’ current views if reasonable.
Reinforces agency primacy in interpreting ambiguous statutes.
4. King v. Burwell (2015)
Citation: 576 U.S. 473
Facts:
The case questioned whether tax credits under the Affordable Care Act applied to federal exchange states.
Issue:
Was Chevron deference appropriate in this major statutory interpretation with significant policy impact?
Held:
The Court declined to apply Chevron deference because the issue was too major and Congress did not clearly delegate authority to the IRS for this interpretation.
Significance:
Introduced the “major questions doctrine” limiting Chevron.
Courts may refuse deference on issues of vast economic and political significance.
Carves out a constitutional check on agency power.
5. Michigan v. EPA (2015)
Citation: 576 U.S. 743
Facts:
EPA interpreted the Clean Air Act to regulate power plants without considering costs.
Issue:
Did the EPA unreasonably interpret the statute, meriting deference?
Held:
The Court held EPA’s interpretation was unreasonable, rejecting deference.
Significance:
Agencies’ interpretations must be reasonable and based on sound policy judgment.
Chevron is not automatic; courts assess reasonableness critically.
Reinforces the importance of rational decision-making in rulemaking.
✅ Summary:
Chevron deference guides courts to defer to reasonable agency interpretations when statutes are ambiguous.
Deference applies primarily to formal rulemaking and adjudication.
Courts retain power to reject unreasonable interpretations.
The major questions doctrine restricts Chevron in cases of great significance.
Agencies can change interpretations, but must justify changes.
Chevron balances agency expertise with judicial oversight.
RELATED Blog
0 comments