Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.

Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
Litigants	Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
Arguedate	October 15, 1983
Decidedate	March 28, 1984
Fullname	Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
Usvol	467
Uspage	837
Parallelcitations	104 S. Ct. 2778; 81 L. Ed. 2d 694
Majority	John Paul Stevens
Joinmajority	Thurgood Marshall, Byron White, Harry Blackmun, Lewis Powell
Concurrence	William Rehnquist (in judgment)
Dissent	Sandra Day O'Connor
Lawsapplied	Administrative Procedure Act

Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. was a landmark decision by the Supreme Court of the United States that established a two-step framework for judicial review of federal administrative agencies' interpretations of statutes. Decided in 1984, the case arose from a dispute over regulations issued by the Environmental Protection Agency interpreting provisions of the Clean Air Act as applied to emissions controls and plant modification. The ruling created what became known as "Chevron deference," shaping relationships among the Supreme Court of the United States, federal administrative agencies such as the Environmental Protection Agency, and litigants including Natural Resources Defense Council and multinational corporations like Chevron Corporation.

Background

The dispute originated in administrative actions by the Environmental Protection Agency under the Clean Air Act and involved enforcement actions by the Natural Resources Defense Council against Chevron Corporation and other industrial defendants. Prior litigation had proceeded through the United States Court of Appeals for the District of Columbia Circuit, a court frequently engaged with challenges to agency rulemaking from parties including American Petroleum Institute and environmental advocacy groups like Sierra Club and Friends of the Earth. Issues implicated statutory interpretation of ambiguous provisions, the scope of agency rulemaking authority under the Administrative Procedure Act, and precedents from the D.C. Circuit and other circuits such as the Second Circuit and Ninth Circuit.

Supreme Court Decision

Writing for the majority, Justice John Paul Stevens articulated a two-step test for judicial review: first, whether Congress had directly spoken to the precise question at issue; second, if the statute was silent or ambiguous, whether the agency's interpretation was "reasonable" and therefore entitled to deference. The opinion invoked doctrines and concepts from prior opinions of the Supreme Court of the United States and referenced statutory construction canons applied by Justices such as Thurgood Marshall and Lewis Powell. The decision produced a majority joined by Justices Harry Blackmun and Byron White; Chief Justice Warren E. Burger had earlier influence on administrative law debates, and contemporary Justices like William Rehnquist and Sandra Day O'Connor offered separate writings reflecting differing judicial philosophies.

Chevron Deference Doctrine

Chevron deference established a framework used by the Supreme Court of the United States and lower federal courts including the United States Courts of Appeals to assess agency interpretations under statutes such as the Clean Air Act, Clean Water Act, Safe Drinking Water Act, and provisions of the Energy Policy Act. The doctrine interacts with the Administrative Procedure Act's rulemaking provisions and with doctrines like Skidmore v. Swift & Co.'s respect accorded to agency interpretations and the Major Questions Doctrine recently invoked by Justices including Neil Gorsuch and Brett Kavanaugh. Chevron's two-step method has been taught in curricula at institutions like Harvard Law School, Yale Law School, and Columbia Law School.

Subsequent Developments and Applications

Lower courts including the D.C. Circuit, Second Circuit, Ninth Circuit, and Federal Circuit applied Chevron in disputes involving regulatory actions by agencies such as the Securities and Exchange Commission, Federal Communications Commission, National Labor Relations Board, and Internal Revenue Service. The doctrine figured centrally in major cases addressing Clean Air Act implementation, Endangered Species Act regulations, Affordable Care Act rules, and Dodd–Frank Wall Street Reform and Consumer Protection Act interpretations. The Supreme Court of the United States revisited principles related to Chevron in later opinions such as those by Justices Antonin Scalia, Ruth Bader Ginsburg, and Stephen Breyer, and in decisions discussing deference doctrines and separation of powers issues.

Criticisms and Legal Debate

Chevron deference has prompted critique from academics at institutions like University of Chicago Law School, Georgetown University Law Center, and think tanks such as the Heritage Foundation and Brennan Center for Justice. Critics including scholars like Antonin Scalia (in his writings), Cass Sunstein, and Erwin Chemerinsky argued that Chevron grants excessive authority to agencies at the expense of the judiciary and legislative intent. Defenders, including commentators affiliated with Brookings Institution and former agency officials from the Environmental Protection Agency and Federal Trade Commission, contended that expertise-based deference promotes coherent administrative regulation and efficient governance. Debates intersect with constitutional doctrines involving the Appointments Clause and the Take Care Clause.

Legacy and Impact on Administrative Law

Chevron's legacy is evident across administrative litigation, academic literature, and public policy debates in venues like the United States Congress and administrative bodies including the Office of Management and Budget. The doctrine shaped the balance of power among the Supreme Court of the United States, federal agencies, and litigants such as Natural Resources Defense Council and corporate actors like Chevron Corporation. Whether Chevron endures, is narrowed, or is overruled remains a central question in contemporary cases and commentary involving Justices such as John Roberts, Samuel Alito, and Clarence Thomas, and in legislative proposals in the United States Congress to recalibrate administrative authority.

Category:United States administrative case law