Administrative Law Cases
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. 467 U.S. 837 (1984) (W|L)
- Petition was filed for review of order of the Environmental Protection Agency. The Court of Appeals, 685 F.2d 718, vacated regulations, and certiorari was granted. The Supreme Court, Justice Stevens, held that Environmental Protection Agency regulation allowing states to treat all pollution-emitting devices within same industrial grouping as though they were encased within single "bubble" was based on permissible construction of term "stationary source" in Clean Air Act Amendments. 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 clearest articulation of the doctrine of "administrative deference," to the point that the Court itself has used the phrase "Chevron deference" in more recent cases.
Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc. 435 U.S. 519 (1978) (W|L)
- The Supreme Court, Mr. Justice Rehnquist, held that: (1) the Commission acted within its statutory authority in considering environmental impact of spent fuel processes in individual licensing proceedings; (2) nothing in the applicable statutes or the circumstances of the case permitted Court of Appeals to review and overturn rule-making proceeding on the basis of procedural devices employed or not employed by the Commission, where the Commission employed at least the statutory minimum; (3) in light of the facts available at the time, procedure adopted by the Commission in requiring intervenors to make showing with respect to alleged energy conservation alternatives “sufficient to require reasonable minds to inquire further,” was within the agency's discretion, and (4) there was nothing to justify nullification of licensing procedures on theory that the Advisory Committee on Reactor Safeguards should have clarified certain report and should have given short explanation, understandable to any layman, of each generic safety concern.
U.S. v. Mead Corp. 533 U.S. 218 (2001) (W|L)
- Importer filed suit challenging tariff classification of its day planners. The Court of International Trade, 17 F.Supp.2d 1004, granted summary judgment to the government. The Court of Appeals for the Federal Circuit, 185 F.3d 1304, reversed, holding that tariff classification ruling was not entitled to Chevron deference or any lesser degree of deference. Importer petitioned for certiorari. The United States Supreme Court, Justice Souter, held that: (1) tariff classification ruling was not entitled to Chevron deference, and (2) ruling was entitled to respect according to degree of its persuasiveness.
Heafey Law Library Research Team