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

Supreme Court of the United States · 1984 · Constitutional Law

Constitutional Lawadministrative lawagency deferencestatutory interpretationChevron deferenceEPAClean Air Actstationary source

Facts

The 1977 Clean Air Act Amendments required nonattainment States to establish permit programs for new or modified major stationary sources of air pollution. EPA adopted a regulation allowing States to define "stationary source" on a plantwide basis, so that changes to one unit within an existing plant would not trigger permit requirements if the plant's total emissions did not increase. Respondents challenged that regulation, arguing that the Act did not permit the "bubble concept." The statutory text and legislative history did not specifically resolve whether "stationary source" had to mean each individual pollution-emitting device or could mean the plant as a whole.

Issue

When Congress has not directly addressed the precise meaning of a statutory term administered by an agency, may a court reject the agency's interpretation and impose its own reading? More specifically, was EPA's plantwide definition of "stationary source" in the Clean Air Act nonattainment permit program a permissible construction of the statute?

Rule

When a court reviews an agency's construction of a statute it administers, it asks first whether Congress has directly spoken to the precise question at issue; if Congress's intent is clear, both court and agency must give effect to that unambiguously expressed intent. If the statute is silent or ambiguous on the specific issue, the court may not impose its own construction but instead asks whether the agency's interpretation is a permissible or reasonable construction of the statute; if so, it must be upheld.

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Congress creates a federal mine-safety program administered by the Mineral Safety Bureau. The statute requires inspections of every "shaft elevator" and separately defines that term as "any lift used to transport miners vertically between underground levels," without further qualification. The Bureau issues a rule exempting elevators used only during night shifts.

If a mining company in Butte, Montana challenges an enforcement action under the rule, how should a reviewing court assess the Bureau's interpretation?

Explanation. The majority establishes a two-step framework. First, the court asks whether Congress has directly spoken to the precise question at issue. If congressional intent is clear, that ends the matter, and both the court and agency must give effect to that unambiguously expressed intent. Here the statute specifically defines "shaft elevator," so the agency cannot carve out a night-shift exemption contrary to that clear command.