Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.

Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), was a case in which the United States Supreme Court set forth the legal analysis for determining whether to grant deference to a government agency's interpretation of its own statutory mandate. Chevron is the Court's most clear articulation of the doctrine of "administrative deference."

Background

Since the Supreme Court's ruling in Marbury v. Madison, 5 U.S.(1 Cranch) 137 (1803), United States federal courts have the authority to judicially review the statutes enacted by Congress, and declare a statute invalid if it violates the Constitution. But the Constitution sets no limits on a government agency's authority. Rather, federal government agencies are given authority through statutes enacted by Congress.

Facts

Congress amended the Clean Air Act in 1977 to address states that had failed to attain the air quality standards established by the EPA (Defendant). "The amended Clean Air Act required these 'nonattainment' States to establish a permit program regulating 'new or modified major stationary sources' of air pollution." 467 U.S. at 840. During the Carter administration, the EPA defined a source as any device in a plant that produced pollution. In 1981, after Reagan was elected, the EPA adopted a new definition that allowed an existing plant to get permits for new equipment that did not meet standards as long as the total emissions from the plant itself did not increase. The Natural Resources Defense Council (NRDC), the Plaintiff, an environmental protection group, challenged the EPA regulation and Chevron (Defendant), an affected party, appealed.

Issue

The issue facing the Chevron court, therefore, was what standard of review should be applied by a court to a government agency's own reading of a statute that gives that agency its authority to act.

Holding

The Court, in an opinion by Justice John Paul Stevens, upheld the EPA's interpretation. A two-part analysis was born from the Chevron decision (called the "Chevron two-step"), where a reviewing court determines (1) whether a statute permits or forbids an agency's interpretation, and (2) if a statute is not clear on step (1), the court decides whether the agency's interpretation of a statute is reasonable or permissible. If an agency's interpretation is reasonable, then the court will defer to the agency's reading of the statute.

Importance

Chevron is probably the most frequently cited case in American administrative law, though some scholars suggest that the decision has had little impact on Supreme Court jurisprudence. A February 2005 citation check on the LexisNexis Shepard's citation service revealed that Chevron has been cited over 12,290 times in court opinions, law review articles, and other secondary sources.

External links

United States Supreme Court cases | United States administrative case law | 1984 in law