Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
| Chevron U.S.A. v. Natural Res. Def. Council | |
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| Argued February 29, 1984 Decided June 25, 1984 |
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| Full case name | Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., et al. |
| Docket nos. |
82-1005 82-1247 82-1591 |
| Citations | 467 U.S. 837 (more)
104 S. Ct. 2778; 81 L. Ed. 2d 694; 21 ERC (BNA) 1049; 14 Envtl. L. Rep. 20,507; 52 U.S.L.W. 4845; 1984 U.S. LEXIS 118
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| Argument | Oral argument |
| Prior history | Natural Resources Defense Council v. Gorsuch, 685 F.2d 718 (D.C. Cir. 1982), cert. granted sub nom. Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 461 U.S. 956 (1983) |
| Subsequent history | Rehearing denied, 468 U.S. 1227 (1984) |
| Holding | |
| Courts must defer to administrative agency interpretations of the authority granted to them by Congress (1) where the intent of Congress was ambiguous and (2) where the interpretation was reasonable or permissible. | |
| Court membership | |
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| Case opinions | |
| Majority | Stevens, joined by Burger, Brennan, White, Blackmun, Powell |
| Marshall, Rehnquist and O'Connor took no part in the consideration or decision of the case. | |
| Laws applied | |
| Clean Air Act Amendments of 1977 (Pub. L. No. 95-95, 91 Stat. 685); 40 C.F.R. 51.18(j)(1)(i)-(ii) (1983) | |
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), was a landmark case in which the United States Supreme Court set forth the legal test for determining whether to grant deference to a government agency's interpretation of a statute which it administers. 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.
Under 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 express limits on how much federal authority can be delegated to a government agency. Rather, limits on the authority granted to a federal agency occur within the statutes enacted by Congress.
Congress amended the Clean Air Act in 1977 to address states that had failed to attain the air quality standards established by the Environmental Protection Agency (EPA) (Defendant). "The amended Clean Air Act required these 'non-attainment' States to establish a permit program regulating 'new or modified major stationary sources' of air pollution." During the Carter administration, the EPA defined a source as any device in a manufacturing plant that produced pollution. In 1981, after Ronald Reagan's election, the EPA, which was headed by Anne M. Gorsuch, 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), an environmental protection group, challenged the EPA regulation in federal court, which ruled in the NRDC's favor.Chevron, an affected party, appealed the lower court's decision.
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