Chevron Deference

Chevron deference originates from the landmark 1984 Supreme Court case Chevron U.S.A., Inc. v. Natural Resources Defense Council. The doctrine establishes that when Congress delegates authority to an administrative agency and the enabling statute is silent or ambiguous on a specific issue, courts should defer to the agency's reasonable interpretation rather than substituting their own judgment.

The two-step Chevron framework proceeds as follows. At Step One, the court asks whether Congress has directly spoken to the precise question at issue. If the statute's meaning is clear, that is the end of the inquiry — the court and the agency must follow Congress's unambiguous intent. At Step Two, if the statute is ambiguous, the court asks whether the agency's interpretation is a permissible construction. The court need not find the interpretation to be the best one, only that it is reasonable.

Chevron deference applies to agency interpretations that carry the force of law, typically those promulgated through notice-and-comment rulemaking or formal adjudication. Informal guidance documents, opinion letters, and policy statements generally receive the lesser Skidmore deference, which weighs the thoroughness of the agency's reasoning, its consistency, and its persuasive power.

The doctrine has been significantly debated and narrowed in recent years. The Supreme Court's decision in Loper Bright Enterprises v. Raimondo (2024) overruled Chevron, holding that courts must exercise independent judgment in interpreting statutes. However, understanding Chevron remains essential because it shaped decades of administrative law and many existing precedents rest on its framework.

Chevron deference reflects a broader debate about the separation of powers, the role of expert agencies in a complex regulatory state, and the proper scope of judicial review.