Case Study - Legal Issue

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1. Identification and description of the legal issue

The issue facing the Chevron court, was what standard of review should be applied by a court to a government agency's own reading of a statute that gives that agency its authority to act. Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)[1], was a case in which the United States Supreme Court 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 most clear articulation of the doctrine of "administrative deference." (1)

Background: Since the Supreme Court's ruling in Marbury v. Madison, 5 U.S.(1 Cranch) 137 (1803), United States federal courts have the authority to judicially review the statutes enacted by Congress, and declare a statute invalid if it violates the Constitution. But the Constitution sets no limits on a government agency's authority. Rather, federal government agencies are given authority through statutes enacted by Congress.(1)

Facts: Congress amended the Clean Air Act in 1977 to address states that had failed to attain the air quality standards established by the EPA (Defendant). "The amended Clean Air Act required these 'nonattainment' States to establish a permit program regulating 'new or modified major stationary sources' of air pollution." 467 U.S. at 840. During the Carter administration, the EPA defined a source as any device in a plant that produced pollution. In 1981, after Reagan was elected, the EPA adopted a new definition that allowed an existing plant to get permits for new equipment that did not meet standards as long as the total emissions from the plant itself did not increase. The Natural Resources Defense Council (NRDC), the Plaintiff, an environmental protection group, challenged the EPA regulation and Chevron (Defendant), an affected party, appealed (1)

2. Identification and description of the legal rule

The administrative rule was to determine whether to grant deference to a government agency's interpretation of its own statutory mandate. In fact, Chevron is the Court's most clear articulation of the doctrine of "administrative deference."

3. Application of the rule to the legal issue

Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)[1], was a case in which the United States Supreme Court 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 most clear articulation of the doctrine of "administrative deference." (1)
When a court reviews an agency's construction of the statute, which it administers, it is confronted with two questions. First, always, is the question ...