Loper Bright Enterprises v. Raimondo
The Supreme Court overruled Chevron U.S.A. v. Natural Resources Defense Council, the 1984 decision that had required federal courts to defer to agencies' interpretations of the statutes they administer whenever the law was ambiguous.
The ruling ends four decades of a foundational doctrine and means that federal courts — not agencies like the EPA, FDA, or OSHA — now have the final word on what ambiguous regulatory laws mean, with broad implications for how federal regulation works.
How it got here: The D.C. Circuit and the First Circuit both applied Chevron deference to uphold a federal fishery monitor-cost rule against challenges from fishing companies; the Supreme Court granted certiorari in both cases limited solely to the Chevron question.
The Case in Depth
What happened
Several family-owned fishing businesses challenged a federal rule requiring them to pay the costs of at-sea government monitors — up to $710 per day, reducing annual vessel returns by as much as 20 percent. They argued the Magnuson-Stevens Act, which governs U.S. fisheries, never authorized the agency to shift those costs onto fishermen. Lower courts upheld the rule by deferring to the agency's interpretation of the statute under Chevron rather than deciding the legal question independently.
The question before the Court
Should courts be required to accept federal agencies' interpretations of ambiguous laws, or should judges independently decide what those laws mean?
The Court's answer
Yes — the Court overruled Chevron, holding that the Administrative Procedure Act (APA) requires courts to exercise their own independent judgment whenever they decide whether an agency has acted within its legal authority. When a statute is ambiguous, courts must use every available tool of legal interpretation to find the best reading — they cannot simply accept any "permissible" reading an agency offers. Courts were always the institution the Constitution charged with saying what the law is, and the APA codified that duty in 1946.
Courts may still treat agency interpretations as persuasive guidance — as they did before Chevron under the older Skidmore framework — and must respect genuine congressional grants of discretionary authority to agencies. But agencies are no longer entitled to automatic deference just because a statute is ambiguous. That is the core Chevron rule, and it is gone.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Federal agencies have relied on Chevron for decades to defend their rules against legal challenge. Without automatic deference, regulated industries can more effectively challenge agency interpretations in court, and judges will independently determine what the law requires. Every area of federal regulation — environmental rules, drug approvals, workplace safety standards, financial oversight — is affected by this shift in interpretive authority.
What changes now
The two fishing cases are sent back to lower courts to decide, without Chevron deference, whether the Magnuson-Stevens Act actually authorizes requiring fishing vessel operators to pay for at-sea government monitors. Going forward, all federal courts must independently interpret ambiguous statutes using traditional legal tools; agency views remain persuasive guidance under the older Skidmore framework but carry no automatic binding weight. Countless existing agency rules that were defended under Chevron may face fresh legal challenges, though prior judicial decisions upholding those rules remain valid.
What this does not decide
The ruling does not automatically invalidate prior court decisions that upheld specific agency actions as lawful under Chevron — those holdings remain in force. It also does not decide whether the fishing observer-cost rule was actually authorized by the Magnuson-Stevens Act — that question returns to the lower courts. The Court explicitly declined to reach the underlying statutory question about fishery management.
Concurrences and dissents
Concurrence — Justice Thomas
Justice Thomas joins the majority in full but writes separately to emphasize a deeper constitutional problem: Chevron violated the separation of powers under the Constitution itself, not just the APA. He argues that Article III's 'judicial Power' has always included the authority to resolve legal ambiguities, so compelling judges to defer to agencies' readings stripped courts of a core constitutional function. Simultaneously, Chevron let executive agencies exercise a form of judicial power the Constitution reserves to courts — an improper transfer of authority that the ruling now corrects.
Concurrence — Justice Gorsuch
Justice Gorsuch agrees Chevron should be overruled and writes at length about what stare decisis actually requires under its common-law roots. He argues past decisions are evidence of the law, not law itself; that consistent, mainstream lines of precedent deserve more respect than isolated departures; and that stray passages in opinions should not be read as statutory commands. Under all three lessons, Chevron — a break from centuries of practice, in tension with constitutional structure and the APA, and built on an under-examined passage that even its author did not intend as a revolution — deserves no stare decisis protection.
Dissent — Justice Kagan
“Those were the days, when we knew what we are not.”Kagan opens her conclusion by lamenting the majority's expansion of judicial power at agencies' expense — quoting Chevron's own reminder that judges are not experts in regulatory fields.
Justice Kagan argues Chevron was correct: Congress would want agencies, not courts, to fill statutory gaps in the regulatory schemes it charges them to administer, because agencies have subject-matter expertise, hands-on regulatory experience, and democratic accountability that courts lack. She contends Section 706 of the APA is silent on the standard for reviewing statutory interpretations and is fully compatible with deference. She also accuses the majority of engineering Chevron's demise through years of deliberate neglect and criticism, then pointing to that self-inflicted decline as proof of unworkability — a tactic she says mocks stare decisis.
How the Court got there
The legal reasoning, step by step
- The Constitution has always assigned courts the duty to say what the law is. From the founding onward, courts exercised independent judgment on legal questions — including statutory interpretation — even while giving respectful weight to executive branch views. A judge was 'not at liberty to surrender, or to waive' independent judgment simply because an agency disagreed. That tradition was never displaced before Chevron.
- The APA, enacted in 1946 as a check on administrative overreach, codified this tradition. Its Section 706 directs that 'the reviewing court shall decide all relevant questions of law' — with no deferential standard prescribed for legal interpretation. Notably, the APA does mandate deference for agency fact-finding and policymaking, but its silence on a deferential standard for legal questions is telling: Congress would have said so if it meant to depart from centuries of judicial practice.
- Chevron (1984) broke sharply from this tradition by requiring courts to defer to any 'permissible' agency interpretation of an ambiguous statute — without mentioning the APA and without acknowledging any doctrinal shift. The Court later justified Chevron as resting on a presumption that Congress implicitly delegates interpretive authority to agencies whenever a statute is ambiguous, trusting their subject-matter expertise and democratic accountability through the President.
- That justification does not hold up. Statutory ambiguity often reflects sloppy drafting or the limits of language — not a congressional intent to let the agency decide. Courts resolve ambiguous statutes every day in cases having nothing to do with agencies; in those cases the ambiguity is not a delegation to anyone, yet courts find the best reading. The same should be true in agency cases: there is always a best reading, and courts — not agencies — have the expertise and constitutional responsibility to find it.
- Stare decisis — the doctrine of judicial adherence to precedent — does not require preserving Chevron. Its reasoning was flawed from the start because it never addressed the APA. Its defining concept of 'ambiguity' has proven hopelessly subjective — courts cannot agree on when a statute is ambiguous enough to trigger deference — making the framework unworkable. And rather than generating reliance, Chevron actually destroyed it by letting agencies reverse their statutory interpretations with each change of administration, leaving regulated parties in constant uncertainty.
- Overruling Chevron does not invalidate prior decisions that upheld specific agency actions as lawful under Chevron — those holdings remain in force under their own stare decisis. Going forward, courts may still look to agency interpretations as persuasive authority under the Skidmore framework, giving weight based on the quality of the agency's reasoning, consistency over time, and expertise. But courts may not mechanically defer to an agency's reading simply because the statute is ambiguous.
Doctrinal impact
Cases affected by this decision
Overrules Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. (467 U.S. 837)
The 40-year-old rule requiring courts to defer to any reasonable agency reading of an ambiguous statute is abolished.
Reaffirms Skidmore v. Swift & Co. (323 U.S. 134)
Courts may still treat agency interpretations as persuasive guidance based on the quality of the agency's reasoning and expertise.