Loper Bright Enterprises v. Raimondo

Supreme Court of the United States · 2024 · Administrative Law

603 U.S. 369 (2024)

Updated July 21, 2026

Administrative LawJudicial ReviewChevron DeferenceAdministrative Procedure ActChevronAPA § 706independent judgmentagency statutory interpretation

Facts

The Magnuson-Stevens Act allows fishery management plans to require onboard observers and expressly assigns observer costs to certain foreign vessels, limited access privilege program vessels, and vessels in the North Pacific Council, with fee caps in some instances. NMFS approved a rule for the Atlantic herring fishery requiring certain domestic vessels to carry observers and, when NMFS did not provide a government-paid observer, to contract for and pay a government-certified third-party observer. Petitioners, who operate in the Atlantic herring fishery, challenged the rule and argued that the MSA does not authorize NMFS to require them to pay those observer costs. The lower courts upheld the rule by relying on Chevron deference to the agency's interpretation of the statute.

Issue

Whether the Administrative Procedure Act permits courts to defer to an agency's interpretation of a statute simply because the statute is ambiguous. More specifically, whether Chevron should be overruled or clarified.

Rule

Under the Administrative Procedure Act, reviewing courts must exercise their independent judgment to decide all relevant questions of law and interpret statutory provisions. Courts may not defer to an agency interpretation of law simply because a statute is ambiguous, though they may give agency views respectful consideration and must respect valid congressional delegations of discretionary authority to agencies.

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The Federal Transit Materials Board, a federal agency, issued a rule interpreting the word "component" in a rail-safety statute to include software updates. In litigation brought by Blue Mesa Rail Systems in Denver, the district court concludes the agency's interpretation is sensible but that the better reading of the statute excludes software updates.

How should the court rule on the statutory question?

Explanation. Under the majority opinion, APA § 706 requires reviewing courts to decide all relevant questions of law using independent judgment. A court may not defer to an agency's interpretation simply because the statute is ambiguous. Even if the agency's reading is sensible or permissible, the court must adopt what it concludes is the best reading, though it may give the agency's view respectful consideration under Skidmore.