State administrative law vs federal administrative law
State Administrative Law vs. Federal Administrative Law
Overview
Both state and federal administrative law govern how administrative agencies operate, but they differ in scope, authority, and procedural frameworks.
Federal Administrative Law: Governs federal agencies operating under federal statutes, primarily governed by the Administrative Procedure Act (APA) of 1946.
State Administrative Law: Governs agencies at the state level, with procedural rules varying by state but often modeled on the APA or local equivalents.
Key Differences
| Aspect | Federal Administrative Law | State Administrative Law |
|---|---|---|
| Governing Statute | Administrative Procedure Act (APA) | Varies by state, often a state APA or equivalent |
| Scope | Federal agencies (e.g., EPA, SEC, FDA) | State agencies (e.g., state health, labor, utilities boards) |
| Judicial Review | Federal courts | State courts, sometimes federal if federal issues arise |
| Procedural Uniformity | More uniform due to APA | More variation; some states have detailed APAs, others less so |
| Influence of Federal Law | Must comply with constitutional and federal law | Must comply with state constitutions and laws; sometimes mirrors federal law |
Landmark Cases Illustrating State vs. Federal Administrative Law
1. Citizens to Preserve Overton Park v. Volpe (1971) – Federal Administrative Law
Facts: Citizens challenged a federal agency's approval of a highway construction project.
Issue: What is the scope of judicial review over federal agency decisions?
Ruling: The Court held that federal courts must conduct a "hard look" review and not rubber-stamp agency actions.
Significance: Established the standard of arbitrary and capricious review under the federal APA.
Key takeaway: Federal administrative actions are subject to thorough judicial review.
2. Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. (1984) – Federal Administrative Law
Facts: Challenged EPA's interpretation of a statute under the Clean Air Act.
Issue: When should courts defer to an agency’s interpretation of ambiguous statutes?
Ruling: Established the Chevron deference, where courts defer to agency interpretation if reasonable.
Significance: Cemented agencies’ expertise and policymaking discretion in federal administrative law.
Key takeaway: Strong judicial deference to federal agencies.
3. County of Los Angeles v. Superior Court (2006) – State Administrative Law (California)
Facts: Involved review of state agency decisions regarding public health regulations.
Issue: The scope of judicial review under California’s Administrative Procedure Act.
Ruling: The California Supreme Court confirmed that state courts have broad authority to review agency decisions under the state APA.
Significance: Demonstrated that state judicial review can be as robust as federal review.
Key takeaway: State APAs provide meaningful procedural safeguards and judicial oversight.
4. Sierra Club v. State Water Resources Control Board (California, 2013) – State Administrative Law
Facts: Sierra Club challenged the state water board's permit approvals.
Issue: Did the state agency comply with procedural requirements under state administrative law?
Ruling: Court required the agency to comply strictly with procedural rules and environmental statutes.
Significance: Reinforced that state agencies must adhere to procedural norms similar to federal requirements.
Key takeaway: State agencies are bound by detailed procedural rules ensuring fairness and transparency.
5. City of Arlington v. FCC (2013) – Federal Administrative Law
Facts: Dispute over jurisdictional interpretation by a federal agency.
Issue: Should courts defer to federal agency’s interpretation of its own jurisdictional authority?
Ruling: The Supreme Court upheld broad deference to federal agencies' jurisdictional interpretations.
Significance: Reinforced federal agencies’ authority and expanded Chevron principles to jurisdictional questions.
Key takeaway: Strong federal agency autonomy.
Comparative Insights
Procedural Similarities: Both federal and state agencies provide notice, opportunity for hearing, and judicial review.
Judicial Deference: Federal courts apply Chevron deference; many states have similar doctrines but vary in application.
Variations in Scope: Federal agencies often deal with national or cross-state issues; state agencies address localized concerns.
Constitutional Basis: Federal administrative law is grounded in the Constitution and federal statutes; state administrative law derives authority from state constitutions and statutes.
Summary Table of Case Lessons
| Case | Jurisdiction | Key Issue | Holding / Significance |
|---|---|---|---|
| Overton Park (1971) | Federal | Judicial review of agency action | Established “hard look” review standard |
| Chevron (1984) | Federal | Agency statutory interpretation | Established Chevron deference |
| County of Los Angeles v. Superior Court (2006) | California (State) | Judicial review of state agency | Affirmed strong state judicial review |
| Sierra Club v. State Water Board (2013) | California (State) | Procedural compliance by state agency | Enforced strict procedural adherence |
| City of Arlington v. FCC (2013) | Federal | Agency jurisdictional deference | Extended Chevron deference to jurisdictional questions |
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