LOPER BRIGHT ENTERPRISES VS RAIMONDO : CASE SUMMARY
The Supreme Court in Loper Bright Enterprises Vs Raimondo (2024) has overruled longstanding Chevron doctrine and held that Judiciary cannot defer to administrative agency’s interpretation of an ambiguity in law that the agency enforces.
FACTS OF THE CASE
In 1976 the Congress passed the Magnuson – Stevens Fishery Conservation and Management Act, which provided for management of marine fisheries. One of the provisions of the act was that National Marine Fisheries Service may require fishing vessels to carry federal monitors on board to enforce agency’s regulations. The budget of National Marine Fisheries Service was decreasing as such it was facing financial constraints to pay monitor charges.
New England Council, a regional business association, tried to find a resolution of this issue. It initiated amendment to New England Fishery Management Plans to the effect that Fishery Industry will pay cost of additional monitoring although there was no such explicit provision under Magnuson -Stevens Act.
Loper Bright Enterprises, a fishery company, challenged this which finally reached to the Supreme Court.
OPINION OF THE COURT
Chevron doctrine as propounded in Chevron U.S.A. Vs. Natural Resources Defense Council, Inc. (1984) has governed interpretations of ambiguous statutes since 1984. Under this doctrine the Courts had to show deference to interpretation of statute by administrative bodies as long they were reasonable. Chevron doctrine had become fundamental principles under Administrative Law over the years.
In this judgment the Supreme Court overruled Chevron. It was held that Chevron doctrine violates Administrative Procedure Act as well as separation of powers envisaged by the Constitution. The Supreme Court observed that statutory interpretation is core judicial function and cannot be deferred to agencies merely because law is ambiguous. Courts must apply independent judgment in interpretation of law. Ambiguities should not be treated as automatic delegation of power of interpretation to administrative agencies.
Justice Kagan delivered dissenting opinion wherein it was observed that eliminating Chevron will create disruptions.
IMPACT OF THE JUDGMENT
Loper Bright Enterprises Vs Raimondo is a landmark judgment in Administrative Law. The judgment creates a new balance between Judiciary and administrative agencies. This judgment will lead to increased judicial scrutiny of laws passed by administrative bodies. There may be increase in legal challenges to several regulations.
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Mukesh Kumar Suman is an advocate and legal author based at Delhi. He regularly appears before various Judicial Forums including NCLT, NCLAT, High Courts and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.