In 1984, the United States Supreme Court decided Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984) (“Chevron”). The “Chevron doctrine” or “Chevron deference” has remained among the most cited and controversial legal doctrines in modern American jurisprudence. Today, 40 years later, the Supreme Court appears poised to overturn Chevron, ushering in a profoundly different regulatory environment.
The Chevron doctrine is a two-pronged test applied by courts in disputes over whether an agency has exceeded its authority to enforce the statutes the agency administers. The first prong examines whether the statute in question directly addresses the matter in question. If the statute addresses the issue, the court gives effect to the clear intent of Congress, and the analysis ends. When a statute is ambiguous, however, as many federal statutes are, the Chevron doctrine requires the court to defer to the agency's own interpretation of the statute, provided only that the interpretation is subjectively "reasonable."