Chevron Deference under Administrative Law
Chevron Deference under Administrative Law
What is Chevron Deference?
Chevron Deference is a principle of administrative law that compels courts to defer to a federal agency’s reasonable interpretation of an ambiguous statute that the agency administers. It reflects the idea that agencies have expertise and policymaking discretion in their areas, so courts should respect their interpretations unless clearly unreasonable.
Origin: Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)
The term “Chevron Deference” comes from this landmark Supreme Court case, which established a two-step test for courts to apply when reviewing an agency’s interpretation of a statute:
The Chevron Two-Step Test
Step 1:
The court asks: Has Congress directly spoken to the precise question at issue?
If yes, then both the court and agency must follow Congress’s intent. The agency's interpretation is rejected if it conflicts with clear congressional intent.
Step 2:
If the statute is ambiguous or silent on the issue, the court asks: Is the agency’s interpretation reasonable?
If yes, the court defers to the agency’s interpretation, even if the court might prefer a different reading.
Why Chevron Deference?
Agencies have expertise in technical or specialized areas.
Agencies are politically accountable through executive oversight.
Courts lack the same institutional competence.
It promotes uniformity and predictability in applying complex statutes.
Application of Chevron Deference
Chevron applies primarily to:
Federal agencies’ interpretations of statutes they administer.
Interpretations that have the force of law, such as formal rules or adjudications.
Not mere policy statements or informal guidance (which may receive less deference).
Important Case Law Beyond Chevron
1. Chevron U.S.A., Inc. v. NRDC (1984)
Facts: The EPA interpreted the Clean Air Act's provisions ambiguously to allow a less stringent pollution standard.
Holding: The Supreme Court upheld EPA’s interpretation because Congress did not directly address the issue, and the agency’s interpretation was reasonable.
Significance: Established the Chevron deference framework.
2. United States v. Mead Corp., 533 U.S. 218 (2001)
Facts: The Court considered whether Chevron deference applies to a tariff classification letter by Customs.
Holding: The Court held that Chevron deference applies only when Congress delegated authority to the agency to make rules with the force of law.
Significance: Clarified limits of Chevron deference; informal agency actions might get Skidmore deference instead (based on persuasiveness).
3. King v. Burwell, 576 U.S. 473 (2015)
Facts: Whether subsidies under the Affordable Care Act applied to federal exchanges.
Holding: The Court declined to apply Chevron deference, interpreting the statute themselves because it was a major question affecting millions.
Significance: Demonstrated exceptions where courts may refuse Chevron deference on “major questions.”
4. City of Arlington v. FCC, 569 U.S. 290 (2013)
Holding: The Court held that courts should apply Chevron deference to agencies' interpretations of their own jurisdictional authority, reinforcing Chevron's scope.
Limits and Criticism of Chevron Deference
Critics argue it gives too much power to unelected bureaucrats.
Some Justices and scholars favor “anti-deference”, urging courts to interpret statutes independently.
The “major questions doctrine” limits Chevron where agencies make decisions with vast economic or political significance.
Congress can always clarify statutes to avoid ambiguity.
Summary
Chevron Deference requires courts to defer to a federal agency’s reasonable interpretation of an ambiguous statute.
The two-step Chevron test asks whether Congress directly addressed the issue and, if not, whether the agency’s interpretation is reasonable.
Key cases like Chevron (1984), Mead (2001), and King (2015) define the boundaries of this doctrine.
Chevron is a foundational principle balancing judicial review and agency expertise in administrative law.
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