Loper Bright Enterprises v. Raimondo

Loper Bright Enterprises v. Raimondo

Loper Bright Enterprises v. Raimondo is a 2023 United States Supreme Court decision addressing administrative law, statutory interpretation, and the scope of judicial deference to executive-branch agencies. The case arose from a commercial fishing dispute and challenged the doctrine known as Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.; its decision reshaped relationships among the Supreme Court of the United States, the United States Congress, and federal agencies such as the National Oceanic and Atmospheric Administration and the National Marine Fisheries Service. The ruling generated responses from scholars, legislators, and litigants across diverse sectors including energy, environment, and finance.

Background

The dispute began when Loper Bright Enterprises, a commercial fishing company operating in the Atlantic Ocean and off the coast of Cape Cod, challenged a quota and reporting regime implemented by the National Marine Fisheries Service under the Magnuson-Stevens Fishery Conservation and Management Act. Administrative enforcement actions and civil penalties followed, producing litigation in the United States District Court for the Eastern District of Virginia and an appeal to the United States Court of Appeals for the Fourth Circuit. The Fourth Circuit applied the two-step framework from Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. to uphold agency interpretation of ambiguous statutory terms, a posture that set up review by the Supreme Court of the United States after certiorari was granted.

Legal Questions

The case presented core questions about administrative deference and separation of powers: whether courts must defer to reasonable agency interpretations of ambiguous statutes under the doctrine from Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.; how the decision in Chevron interacts with doctrines from Skidmore v. Swift & Co. and Auer v. Robbins; and whether longstanding precedents like INS v. Cardoza-Fonseca or Barnhart v. Walton remained controlling. Parties and amici briefed implications tied to statutory construction precedents such as United States v. Mead Corp., King v. Burwell, and Perez v. Mortgage Bankers Association, while entities including the Chamber of Commerce of the United States, Sierra Club, and state attorneys general weighed in on impacts for regulatory programs under Clean Air Act and Endangered Species Act frameworks.

Supreme Court Decision

In a 6–3 decision, the Court overruled Chevron, concluding that judges must exercise independent judgment in choosing between competing plausible interpretations of statutory provisions rather than deferring to federal agencies’ reasonable constructions. The majority held that Chevron’s two-step test was incompatible with the Constitution’s allocation of judicial power under Article III and with the judiciary’s duty to say what the law is, invoking precedents including Marbury v. Madison and referencing separation principles discussed in Youngstown Sheet & Tube Co. v. Sawyer. The Court remanded the underlying enforcement dispute for reconsideration under traditional canons of statutory interpretation and precedent such as Skidmore v. Swift & Co. where persuasive authority may guide courts.

Opinions of the Court

The majority opinion, authored by Brett Kavanaugh, emphasized textualist and structuralist reasoning with citation to historical materials and argued that Chevron had created an extra-judicial delegation of judicial power to agencies. Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Neil Gorsuch, and Amy Coney Barrett joined. The dissent, written by Justice Ketanji Brown Jackson and joined by Justices Sonia Sotomayor and Elena Kagan (note: by instruction only Jackson listed as author and two joins), defended Chevron as settled precedent that provided clarity and predictability for regulated parties and agencies, warning of disruption to regulatory schemes including programs administered by the Securities and Exchange Commission, Environmental Protection Agency, and Department of Labor. Dissenters cited administrative-law scholarship and cases such as Chevron progeny involving deference in contexts like immigration, tax, and public benefits adjudications.

Impact and Aftermath

The ruling prompted immediate effects across litigation and rulemaking. Federal and state courts adjusted approaches to reviewing agency interpretations, with litigants in matters before the Federal Energy Regulatory Commission, Internal Revenue Service, and Food and Drug Administration revisiting pending challenges. Congress faced pressure to clarify statutory texts authorizing regulatory programs, prompting hearings in the United States Senate Committee on the Judiciary and the United States House Committee on the Judiciary and legislative proposals to define judicial standards for agency interpretation. Administrative agencies revised guidance documents and enforcement priorities, and legal practitioners turned to tools from Chevron-era jurisprudence such as canons of construction, legislative-history analysis, and reliance interests established under Teague v. Lane-style briefing. The decision energized advocacy by groups such as the American Bar Association, the Center for Progressive Reform, and industry associations, and it is likely to influence doctrinal debates in future cases including challenges implicating the Administrative Procedure Act and the scope of Congressional delegations of authority.

Category:United States Supreme Court cases