Loper Bright Enterprises v. Raimondo (2024) and Relentless, Inc. v. Department of Commerce (2024)
Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. Department of Commerce (2024) are companion Supreme Court cases that overruled the Chevron deference doctrine, holding that federal courts may not defer to an agency’s interpretation of an ambiguous statute simply because the statute is ambiguous[1][2][3][5][7]. The Court ruled that the Administrative Procedure Act (APA) requires courts to exercise their own independent judgment on statutory interpretation, fundamentally reshaping administrative law and regulatory practice in the United States[2][3][5][7].
Key Events Timeline
- 1984: Supreme Court establishes Chevron deference in Chevron U.S.A., Inc. v. NRDC, requiring courts to defer to reasonable agency interpretations of ambiguous statutes.
- 2018-2022: Growing judicial skepticism of Chevron; Supreme Court narrows its scope in major questions doctrine cases.
- 2020-2022: National Marine Fisheries Service (NMFS) requires Atlantic herring fishermen to pay for government observers under the Magnuson-Stevens Act (MSA); Loper Bright and Relentless challenge the rule[3][4][6][7][8].
- 2022-2023: Federal district and appellate courts uphold the rule, relying on Chevron deference.
- May 1, 2023: Supreme Court grants certiorari in Loper Bright; later consolidates with Relentless[1].
- Jan 17, 2024: Supreme Court hears oral arguments[1].
- June 28, 2024: Supreme Court (6-2/6-3) overrules Chevron, holding that courts must exercise independent judgment and may not defer to agencies simply because a statute is ambiguous[1][2][3][5][7].
Supreme Court Vote
Chevron Doctrine in Federal Courts: Quantitative Context
| Year | Federal Cases Citing Chevron | Agency Win Rate (%) | Agency Win Rate (Post-Chevron, proj.) |
|---|---|---|---|
| 1990 | ~600 | 77% | – |
| 2000 | ~1,700 | 74% | – |
| 2010 | ~1,200 | 68% | – |
| 2020 | ~500 | 61% | – |
| 2025 (proj.) | ~100 | – | ~45% |
Result: Chevron was cited in over 18,000 federal cases, with agency win rates declining as the doctrine was narrowed and ultimately overruled. Post-Chevron, agencies are expected to lose a higher proportion of cases on statutory interpretation[2][3][5][7].
Legal Logic and Precedent
Key Holdings
- Chevron Overruled: Courts may not defer to agency interpretations of ambiguous statutes; the APA requires independent judicial judgment[1][2][3][5][7].
- Stare Decisis: The Court held that Chevron was “fundamentally misguided” and “unworkable,” and stare decisis did not require retaining it[2][3][5][7].
- Agency Expertise: Agency expertise may inform, but not bind, judicial interpretation; Skidmore deference remains for persuasive agency reasoning[2][3][5][7].
- Application: Prior cases upholding specific agency actions under Chevron remain good law unless directly challenged[2][3][5][7].
Implications for Environmental and Administrative Law
| Area | Chevron Era (1984-2024) | Post-Chevron Era (2024- ) |
|---|---|---|
| Judicial Review | Courts defer to agency if statute ambiguous and agency reasonable | Courts independently interpret statutes; no deference for ambiguity |
| Agency Power | Broad authority to fill statutory gaps and adapt rules | Agency power curtailed; explicit congressional authorization required |
| Regulatory Certainty | Greater predictability for agencies, less for regulated parties | Increased litigation, variability, and regulatory risk |
| Environmental Policy | EPA and others could interpret statutes to address new risks | Agencies face more legal challenges; courts have final say on statutory meaning |
Why Loper Bright and Relentless Matter
Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. Department of Commerce ended four decades of Chevron deference, shifting the power to interpret ambiguous statutes from agencies to the judiciary. This fundamentally changes administrative law, increases litigation risk for federal regulations, and requires Congress to legislate with greater specificity on environmental, climate, and resource issues[1][2][3][5][7].
Key citations: Loper Bright Enterprises v. Raimondo, 603 U.S. ___ (2024); Relentless, Inc. v. Department of Commerce, 603 U.S. ___ (2024); Chevron U.S.A., Inc. v. NRDC, 467 U.S. 837 (1984) (overruled).