Chevron USA Inc. v. Natural Resources Defence Council

1984

Venue: SCOTUS

Facts: EPA requires states that have not attained their air quality goals to implement a program governing new sources of air pollution. There's controversy as to what counts as a "new source:" is it individual things, or can they be grouped?

Posture: Ct. App. for DC Circuit says EPAs regs are contrary to the law.

Issue: Is EPA's decision to treat all pollution-emitting devices within the same industrial grouping as part of a single "bubble" based on a permissible construction of the law?

Holding: Yes. Reversed.

Rule: Where a statute is silent or ambiguous on a particular issue, the court is deferential to the agency, unless the construction of the law is arbitrary, capricious, or manifestly contrary to statute.

Reasoning: The power of an administrative agency to administer a congressionally mandated program implies the power to fill in gaps in the statute. Words in the statute can be read either individually, or as part of a related unit, so that a list might be seen as having a meaning in addition to the things it enumerates. The EPA is just saying that this list of industrial sources could be seen as describing industrial sources in general or something like that. It's not for the court to make policy decisions about pollution: take this fight to congress.

Dicta: Sometimes courts do have to reconcile competing policy interests, but it is better for agencies or legislatures, who are accountable to the people, to make these decisions.