Loper Bright Enterprises v. Raimondo

Jump to content

From Wikipedia, the free encyclopedia

(Redirected from Loper Bright v. Raimondo )

2024 United States Supreme Court case

Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024), is a landmark decision [1] of the Supreme Court of the United States in the field of administrative law , the law governing regulatory agencies. Together with its companion case, Relentless, Inc. v. Department of Commerce, it overruled the principle of Chevron deference established in _Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. _ (1984), which had directed courts to defer to an agency's reasonable interpretation of an ambiguity in a law that the agency enforces.[2] [3]

In lieu of Chevron, the decision assigns the determination of congressional ambiguity to the judicial branch, with executive agency expertise still to be considered under the weaker Skidmore deference . Existing rules and case law already decided under Chevron deference were to remain in place from this decision.

Both cases originated from fishing companies challenging a rule established by the National Marine Fisheries Service (NMFS) for fishing companies to pay for the cost of federal monitors that may be assigned to their boats, under authorization of the Magnuson–Stevens Fishery Conservation and Management Act (Magnuson–Stevens Act (MSA)). The company claimed that the Act did not allow NMFS to pass the monitors' costs to the fishing companies, challenging Chevron deference that was applied in favor of the NMFS during lower court hearings.[4]

Background

[(https://en.wikipedia.org/w/index.php?title=Loper_Bright_Enterprises_v._Raimondo&action=edit&section=1 "Edit section: Background")
]

In 1976, Congress passed the Magnuson–Stevens Fishery Conservation and Management Act , which was intended to provide for the management of marine fisheries in United States waters.[5] One of the Act's provisions authorizes the National Marine Fisheries Service (a subsidiary agency of the United States Department of Commerce ) to require fishing vessels to "carry" federal monitors on board to enforce the agency's regulations, particularly to prevent overfishing.[6]

The New England Fisheries Management Council (NEFMC) is a council that regulates fisheries in federal waters under the Magnuson-Stevens Fishery Conservation and Management Act. NEFMC develops fishery management plans for fisheries off the coasts of Maine , New Hampshire , Massachusetts , Rhode Island , and Connecticut . One such fishery is the Atlantic herring fishery. Unlike in North Pacific and foreign fisheries, the Magnuson–Stevens Act (MSA) does not explicitly require Atlantic herring fisheries to pay the costs of federal monitors. In addition, budgets for NMFS had been falling in recent years.[_citation needed
] As a result, NMFS had been unable to pay for increased monitor coverage in the Atlantic herring fishery.[citation needed
_]

Starting in 2013, the NEFMC started to implement a workaround to this issue. It began to develop an amendment to the New England fishery management plans that would give the council the power – though not explicitly given in the MSA – to require the fishing industry to pay the costs of additional monitoring. The NEFMC submitted this amendment to the NMFS, which in February 2020 published its final rule establishing a standardized process that would require industry-funded monitoring across New England fisheries.

Prior precedent

[(https://en.wikipedia.org/w/index.php?title=Loper_Bright_Enterprises_v._Raimondo&action=edit&section=2 "Edit section: Prior precedent")
]

The Supreme Court ruled in _Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. _, 467 U.S. 837 (1984), that courts must defer to the authority of an administrative agency's interpretation of a statute whenever both the intent of Congress was ambiguous and the agency's interpretation is reasonable or permissible. In its opinion, the Court outlined a two-step test on when to grant deference, known as Chevron deference. The Court reasoned that ambiguities in statute may be a delegation of authority from Congress, thus limiting a federal court's ability to review an agency's interpretation of the law. In the specific case at the heart of Chevron, the challenge arose from the United States Environmental Protection Agency 's interpretation of what defined a source of production of pollution in its authority granted by Congress through the Clean Air Act .

In the first step of the test, the Court would ask whether there was an unambiguous expression of Congressional intent contained within the statute. If so, then the Court must yield to Congressional intent. If not, then the Court would proceed with the second step of the test. It would ask whether the agency's application of the statute was based on a "reasonable" interpretation of ambiguous wording. If so, then the Court would defer to the agency's interpretation of the statute. If not, then the agency's interpretation would likely be deemed impermissible. Here, reasonability was determined by the specific factual circumstances present in the case.

Since being handed down, Chevron had become among the most frequently cited cases in American administrative law.[7] Over 17,000 lower federal court decisions and 70 decisions by the Supreme Court itself cited Chevron.[8] Between 2003 and 2013, circuit courts applied Chevron in 77% of decisions regarding regulatory disputes.[9]

In years prior to the current case, the Supreme Court, with a majority of conservative justices, had been seen as leading towards weakening or overturning Chevron. In _West Virginia v. EPA _, 597 U.S. 697 (2022), the Supreme Court ruled against parts of an emissions-related rule created by the United States Environmental Protection Agency , asserting that the agency did not consider the costs of implementation of their rule. While this case did not overturn Chevron, it defined the major questions doctrine that was used in future cases to question the interpretation of administrative law when the financial impact of the law had not been considered by the agency,[10] such as in _Biden v. Nebraska _, 600 U.S. 477 (2023), which blocked President Joe Biden 's student loan forgiveness project under the HEROES Act for failing to account for its financial cost to states.

Lower courts

[(https://en.wikipedia.org/w/index.php?title=Loper_Bright_Enterprises_v._Raimondo&action=edit&section=3 "Edit section: Lower courts")
]

Loper Bright Enterprises is a New Jersey –based family-owned herring fishing company operating in the waters of New England ; the company estimated the cost of federal monitoring to be about $700 per day.[11] In February 2020, Loper Bright filed a lawsuit in the United States District Court for the District of Columbia alleging that the MSA did not authorize the NMFS to mandate industry-funded monitoring of herring fisheries. The District Court, applying Chevron, granted summary judgment in favor of NMFS. Despite Chevron providing deference

…