Relentless v. Department of Commerce
Overview
Overview
Relentless, Inc. v. Department of Commerce was a companion case to Loper Bright Enterprises v. Raimondo, decided together in June 2024. The Supreme Court overruled Chevron U.S.A. v. Natural Resources Defense Council, holding that courts must independently interpret ambiguous statutes rather than deferring to agency interpretations.
The Facts
Facts
New Jersey fishing companies challenged a National Marine Fisheries Service rule requiring them to pay for federal monitors aboard their vessels, arguing it exceeded statutory authority. The case was consolidated with Loper Bright, the vehicle for overruling Chevron deference.
The Issue
Issue
Whether courts owe deference to federal agencies' interpretations of ambiguous statutes under Chevron U.S.A. v. NRDC, and whether the NMFS rule requiring industry-funded monitors exceeded statutory authority.
The Rules
Rule
Courts, not agencies, have the final authority to say what the law means; Marbury v. Madison requires judicial interpretation of statutes, and Chevron deference was inconsistent with the APA's requirement of independent judicial review of agency legal conclusions.
The Application
Analysis
The fishing companies' challenge to the NMFS monitor requirement, which would previously have been defeated by Chevron deference to an agency interpretation, now entitled them to independent judicial review of the agency's legal reasoning. Under the Court's new standard, courts must independently determine whether the NMFS correctly read the statute to authorize industry-funded monitors rather than granting the agency's interpretation controlling weight. This shift eliminated the presumption that had consistently favored agency legal interpretations in cases of statutory ambiguity, allowing regulatory challenges to turn on the court's own understanding of the law rather than automatic deference to the agency.
The Conclusion
Conclusion
Court ruled 6-3 with the majority overruling Chevron. Roberts wrote the opinion. Agencies may no longer demand judicial deference to their statutory interpretations; courts must conduct independent review.
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