The majority opinion stated, "Courts must independently assess whether an agency has acted within its statutory authority, as required by the APA [Administrative Procedure Act]."
For more than four decades, judicial review of agency interpretations of statutes has followed Chevron's well-known two-step framework. At the first step, courts determined if Congress had "directly spoken to the precise question at issue." If not, the agency's interpretation was upheld at the second step unless it was deemed unreasonable. This approach often allowed statutes to shift meanings between administrations, enabling agencies to find broad statutory grants supporting specific policies or political goals. Chevron had been cited in over 18,000 federal court decisions and supported hundreds of agency actions, influencing countless other decisions behind the scenes.
https://www.highrevenuenetwork.com/vcx17vfy?key=c42dcd48c6d4bd53d90f1961f801f5e2
In Loper Bright, the Supreme Court ruled that Chevron deference conflicts with the APA and courts' primary duty to interpret congressional laws. The majority relied on APA language assigning courts the authority to decide legal questions, including the meaning of agency actions, contrasting with pre-New Deal precedents emphasizing respect rather than blind adherence to agency determinations.
Furthermore, the Court rejected Chevron's application based on stare decisis, finding it "fundamentally misguided" and "unworkable" due to ongoing ambiguity in defining statutory clarity. Despite dissenting views, the Court argued that Chevron had not fostered substantial reliance and instead fragmented into various exceptions like "Chevron Step Zero" and the Major Questions Doctrine. Loper Bright thus abandoned Chevron in its entirety rather than continuing to modify its shortcomings.
While Loper Bright marks a significant shift, its impact may unfold gradually or revolutionarily. The majority cautioned against overturning precedents based solely on Chevron reliance but suggested such reliance could indicate a prior decision's error. This could affect judicial precedents, agency rulemakings, and final actions dependent on Chevron deference, prompting legal challenges.
Chevron's demise does not end deference entirely. The Court acknowledged Congress's authority to delegate discretionary power to agencies, constrained by constitutional limits like the Non-Delegation Doctrine. Agencies may still apply deference within the arbitrary-and-capricious standard, interpreting laws against new factual contexts.
While predictions of Chevron's demise triggering the collapse of the regulatory state may exaggerate, Loper Bright will fundamentally alter legislative drafting, judicial interpretation of statutes, and potentially internal agency decision-making processes.