U.S. Overturns Chevron Doctrine

Gardner Law
Contact

Gardner Law

The United States Supreme Court ended the 40-year-old Chevron doctrine which directed federal courts to give deference to administrative agencies’ reasonable interpretations of ambiguous federal statutes. The June 28, 2024 decision will significantly impact federal agencies’ rulemaking and enforcement of federal laws related to a wide variety of administrative laws, including those related to the FDA.

The Supreme Court held that courts must exercise their independent judgment when deciding if an agency acted within its statutory authority cannot defer to an agency’s interpretation of ambiguous laws.

The Court determined that Chevron conflicts with the Administrative Procedures Act (APA) that courts and not individual agencies decide all relevant questions of law and should interpret statutory provisions. Ambiguities in the law are not implicit delegations of authority to agencies the Court stated, because the agencies have no “special competence in resolving statutory ambiguities.” Thus the courts should not declare a particular party’s reading of a statute as permissible, but should “use every tool at their disposal to determine the best reading of the statute and resolve the ambiguity.”

The court did state that the decision does not call into question previous decisions that relied on Chevron. A statement the court hopes will stave off hundreds of potential challenges to such decisions.

The decision has significant implications for the FDA, which given its scientific underpinnings will have to be even more rigorous in making rules related to the industries it regulates.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Gardner Law | Attorney Advertising

Written by:

Gardner Law
Contact
more
less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

  • Increased visibility
  • Actionable analytics
  • Ongoing guidance

Gardner Law on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide