Review of mixed agency fact-law determinations
What Are Mixed Fact-Law Determinations?
Mixed questions of fact and law arise when an agency must interpret the law in light of specific factual findings.
Unlike pure questions of fact (which agencies often find first-hand) or pure questions of law (which courts usually decide), mixed questions involve applying legal standards to factual circumstances.
These determinations are common in administrative law, such as evaluating whether certain conduct violates regulatory standards based on facts.
Why Is the Review of Mixed Questions Important?
Agencies often have specialized expertise in both fact-finding and applying regulatory law.
Courts must decide to what extent to defer to agency conclusions on mixed questions.
The review standard affects agency power and judicial oversight balance.
Standards of Judicial Review
De novo review: Courts give no deference and decide the issue anew.
"Substantial evidence" or "clearly erroneous": Courts defer to agency factual findings if supported by evidence.
Chevron deference: Courts defer to reasonable agency interpretations of ambiguous statutes.
Skidmore deference: Agency interpretations are given weight based on persuasiveness.
Mixed questions often get a "some deference" approach, but courts vary.
Key Case Laws on Review of Mixed Agency Fact-Law Determinations
1. Universal Camera Corp. v. NLRB (1951) — U.S. Supreme Court
Background:
Dispute over whether the National Labor Relations Board’s (NLRB) decision was supported by substantial evidence.
Issue:
How much deference courts should give to agency findings combining facts and legal interpretation.
Decision:
The Court ruled that courts must review the entire record to ensure substantial evidence supports the agency’s conclusion.
Significance:
Established substantial evidence as the standard for reviewing agency fact findings.
Recognized that agencies can interpret facts within their expertise but courts retain oversight.
2. FCC v. Fox Television Stations, Inc. (2009) — U.S. Supreme Court
Background:
FCC’s policy on indecency standards was challenged.
Issue:
Whether the FCC’s interpretation of its own rules applied correctly to specific broadcasts.
Decision:
The Court gave Chevron deference to FCC’s reasonable interpretation of ambiguous rules.
Significance:
Applied deference to agency mixed questions involving regulatory interpretation and factual context.
Confirmed agencies’ authority in interpreting their own rules.
3. Gonzales v. Oregon (2006) — U.S. Supreme Court
Background:
The Department of Justice challenged Oregon’s Death with Dignity Act.
Issue:
Whether the Attorney General’s interpretation of the Controlled Substances Act to prohibit physician-assisted suicide was reasonable.
Decision:
The Court ruled that the agency’s interpretation was not entitled to Chevron deference because Congress had not delegated that authority.
Significance:
Highlighted limits of Chevron deference in mixed fact-law questions where agency lacks clear congressional authorization.
4. NLRB v. Hearst Publications, Inc. (1944) — U.S. Supreme Court
Background:
NLRB found a labor dispute existed, impacting collective bargaining rights.
Issue:
Whether the Board’s mixed fact-law determination was binding.
Decision:
The Court upheld the NLRB’s findings unless clearly unreasonable.
Significance:
Showed strong deference to agency fact-law determinations in labor law context.
Supported agency expertise in applying law to complex facts.
5. Auer v. Robbins (1997) — U.S. Supreme Court
Background:
The Department of Labor interpreted its own regulations regarding compensable work time.
Issue:
Whether courts should defer to agency interpretations of their own regulations.
Decision:
The Court held that agencies’ reasonable interpretations of their own ambiguous regulations warrant deference.
Significance:
Extended deference to mixed questions involving agency regulation interpretation and factual application.
Sometimes called “Auer deference.”
Summary
Mixed agency fact-law determinations involve applying legal standards to agency-found facts.
Courts generally afford some level of deference to agencies due to their expertise but retain judicial oversight.
Substantial evidence and Chevron or Auer deference frameworks guide review.
The balance varies by context, statutory authority, and agency expertise.
Key cases like Universal Camera, Chevron, and Auer form the foundation of modern review standards.
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