In the most important fishing case school leaders will ever read, the U.S. Supreme Court overturned the Chevron doctrine, which required courts to defer to federal agencies’ interpretations of ambiguous or silent statutes. The Court found that Chevron‘s deference framework conflicts with the Administrative Procedure Act (APA), which requires courts to independently decide all relevant questions of law. As a result, courts now will exercise their own judgment in interpreting statutes and are not required to defer to agencies’ expertise and interpretations when statutes are ambiguous.
In the original Chevron case, Chevron U.S.A, Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), the Supreme Court created the Chevron doctrine to address the Environmental Protection Agency’s interpretation of the Clean Air Act. The doctrine required courts to defer to agency interpretations of ambiguous statutes, recognizing their expertise in their fields. Chevron was subsequently overturned after it came under scrutiny in two sister cases, Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. Department of Commerce, where the Supreme Court reviewed the National Marine Fisheries Service’s (NMFS) rule requiring fishermen to pay for government-certified observers.
Overturning Chevron has practical implications, as it changes how courts interpret and apply statutes and is likely to lead to greater scrutiny of federal regulations and, accordingly, increased litigation. In the education context, it could affect federal regulations on topics such as IDEA, Title IX, website accessibility standards, FLSA exemption thresholds, and more.
Please contact Pam Simaga or Jason Manning, or any of our other attorneys, with questions about the impact on Loper Bright and Relentless, Inc. on your schools.
