News & Analysis as of

Corner Post Inc v Board of Governors of the Federal Reserve System Administrative Procedure Act Judicial Authority

Venable LLP

A "Tsunami of Lawsuits Against Agencies"? Taking Stock of the Post-Chevron Government Contracting World

Venable LLP on

The U.S. Supreme Court's blockbuster decision in Loper Bright Enterprises v. Raimondo overruled a 40-year-old case (Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.) that required courts to defer to agencies'...more

Skadden, Arps, Slate, Meagher & Flom LLP

Insights - September 2024

In this edition of Insights, we take a closer look at the megadeals and sponsor transactions driving recent M&A activity, the importance of staying ahead of the risks in AI development and deployment, and other diverse...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Decisions Curtail Regulatory Agencies’ Powers, Making It Easier To Challenge Rules

The U.S. Supreme Court’s 2023 term is another chapter in the Roberts Court’s trend of shifting power away from administrative agencies and into the hands of courts....more

Holland & Knight LLP

What's Next for the Regulatory Landscape Post-Chevron?

Holland & Knight LLP on

For nearly 40 years and in more than 18,000 judicial opinions, federal courts have used the Chevron doctrine to defer to an agency's reasonable interpretation of an ambiguous statute. On June 28, 2024, the U.S. Supreme Court...more

Conn Maciel Carey LLP

Destabilized But Not Yet Deconstructed: Analysis of This Momentous SCOTUS Term for the Administrative State

Conn Maciel Carey LLP on

The 2023-2024 Term of the United States Supreme Court will undoubtedly have far-reaching implications in a number of areas, but perhaps most significantly—at least for regular readers of the OSHA Defense Report blog—with...more

McDermott Will & Emery

How Three SCOTUS Decisions Could Impact Healthcare Organizations’ FCA and Agency CMP Litigation Strategies

McDermott Will & Emery on

At the end of the 2024 term, the executive branch struck out when the US Supreme Court issued three separate decisions along ideological lines that have the potential to materially weaken the enforcement authority of federal...more

Stoel Rives LLP

Restart the Clock: SCOTUS Expands the Timeframe to Challenge Agency Actions

Stoel Rives LLP on

Why are environmental professionals talking about the Federal Reserve Board? Because the Supreme Court, on July 1, 2024, ruled that the APA’s six-year statute of limitations (SOL) for facial challenges to agency regulations...more

Paul Hastings LLP

The Post–Chevron Future: Litigating Against Administrative Agencies Following Loper and Corner Post

Paul Hastings LLP on

Over the last few weeks, the Supreme Court issued two long-awaited decisions that are each significant in their own right, but, together, will drastically reshape the future of litigation against administrative agencies—and...more

Partridge Snow & Hahn LLP

Two Supreme Court Decisions Shift the Ground for Legal Challenges to Federal Agency Actions

The Supreme Court has now concluded its most recent term, and in its final two days handed down two decisions with major implications in the area of administrative law (each by a 6-3 margin).  And while their precise...more

Cooley LLP

In Corner Post, SCOTUS takes another swipe at the administrative state

Cooley LLP on

This term, SCOTUS delivered two big wallops to the administrative state in the decisions eliminating Chevron deference (Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. Dept of Commerce, see this Pubco post) and...more

Jenner & Block

Client Alert: How Recent Supreme Court Decisions May Impact EHS Agencies and Regulations

Jenner & Block on

The Supreme Court’s recent term is likely to be remembered as one that significantly affected the long-standing roles and responsibilities of federal agencies, including the deference afforded to their interpretations of...more

K&L Gates LLP

Corner Post Magnifies Regulatory Uncertainty After Loper Bright

K&L Gates LLP on

In its last opinion of this term, the US Supreme Court in Corner Post v. Board of Governors of the Federal Reserve System significantly extended the timeframe in which courts can review certain current and future regulations....more

Skadden, Arps, Slate, Meagher & Flom LLP

Prequel to Loper Bright Shows What Decisions May Look Like After Chevron’s Demise

In Garland v. Cargill, the U.S. Supreme Court held that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) exceeded its statutory authority by issuing a rule that classifies bump stocks as “machineguns” under the...more

Davis Wright Tremaine LLP

The Administrative State After Jarkesy, Loper Bright, and Corner Post – Context and Consequences

A Historic Term for Administrative Law - This month we wrote extensively on both the Loper Bright/Relentless decisions, which overturned the Chevron doctrine, and the Jarkesy decision, which dealt a significant blow to the...more

Latham & Watkins LLP

US Supreme Court Curtails Agency Power: Implications for Fintech and Crypto

Latham & Watkins LLP on

Recent Supreme Court administrative law rulings change the power dynamic between the executive and the judiciary in critical areas of statutory interpretation, enforcement, and immunity from legal challenge....more

Steptoe & Johnson PLLC

Two Major SCOTUS Decisions Changing Federal Regulation Landscape

Steptoe & Johnson PLLC on

In the final days of the term that just ended, the Supreme Court of the United States (SCOTUS) issued two major decisions changing the federal regulation landscape – Loper Bright and Corner Post....more

Stevens & Lee

A New Arena for Future Challenges to CMS Regulations – the Overturn of Chevron

Stevens & Lee on

On June 28, 2024, the Supreme Court overruled Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc., and consequently invalidated the “Chevron Deference” — a cornerstone of administrative law since 1984. In the 6-3 decision...more

Hinshaw & Culbertson LLP

[Commentary] A Trilogy of U.S. Supreme Court Decisions Empower Regulated Entities to Challenge Agency Regulations and Actions

In a trilogy of cases decided at the end of this term, the United States Supreme Court made significant changes to the administrative law terrain by: eliminating Chevron deference....more

Schwabe, Williamson & Wyatt PC

Chevron is Gone: How Will the Real Estate and Construction Industry be Impacted?‎

On June 28, 2024, the Supreme Court overruled the Chevron doctrine that had guided courts’ review of agency actions the past 40 years. The Chevron doctrine required courts to defer to a federal agency’s reasonable...more

Schwabe, Williamson & Wyatt PC

The Supreme Court’s Latest Rulings on Administrative Agencies: Implications for ‎Consumer Product Companies

In the final week of this year’s Supreme Court term, the Court issued several decisions that alter the role of federal agencies in the way laws are interpreted and enforced, and thus the way that business will be done in the...more

Schwabe, Williamson & Wyatt PC

Supreme Court Opinions Overturn Chevron and Modify the Statute of Limitations Allowed by Lower Courts

On June 28, the Supreme Court handed down Loper Bright Enterprises v. Raimondo, which overturned the prior Supreme Court precedent, articulated in Chevron v. Natural Resource Defense Council, Inc. and known as “the Chevron...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Opens the Door to More Rule Challenges by Extending Accrual Date for APA Cases

In Corner Post v. Board of Governors of the Federal Reserve System, the U.S. Supreme Court held the six-year statute of limitations under 28 U.S.C. §2401 for challenging federal agency action under the Administrative...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court’s Overruling of Chevron Deference to Administrative Agencies’ Interpretations of Statutes Will Invite More...

In the consolidated cases Loper Bright Enterprises v. Raimondo, Secretary of Commerce and Relentless, Inc. v. Department of Commerce, the U.S. Supreme Court overruled Chevron v. NRDC, the 1984 case that established the...more

J.S. Held

Crosscurrents: Companies Face Regulatory Uncertainties in Wake of SCOTUS Decisions

J.S. Held on

Recent SCOTUS Decisions Expand Litigants’ Ability to Challenge Federal Agency Regulations - Federal agencies are under attack. Recent decisions from the United States Supreme Court are eroding long standing principles of...more

Adams and Reese LLP

‘Whole New Ball Game’ – SCOTUS Delivers Another Hit to Federal Agencies in Corner Post Decision

Adams and Reese LLP on

Federal agencies may need to call the bullpen for a relief pitcher after the last two weeks of hits delivered by the Supreme Court of the United States. The default limitations period for Administrative Procedure Act...more

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