Supreme Court’s role in narrowing agency authority
🧑⚖️ 1. FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (2000)
📌 Facts:
The Food and Drug Administration (FDA) attempted to regulate tobacco products under its authority to regulate “drugs” and “devices” under the Food, Drug, and Cosmetic Act.
⚖️ Holding:
The Court ruled the FDA lacked authority to regulate tobacco because Congress had repeatedly declined to give the FDA such power, even while regulating tobacco in other laws.
Regulatory authority must be clearly granted by Congress, especially in economically and politically significant areas.
💥 Impact:
Introduced the early form of the “major questions doctrine.”
Sent a strong message that agencies cannot infer authority over controversial sectors from general statutes.
🧑⚖️ 2. Gonzales v. Oregon, 546 U.S. 243 (2006)
📌 Facts:
The U.S. Attorney General attempted to block Oregon’s Death with Dignity Act (assisted suicide law), using the federal Controlled Substances Act as justification.
⚖️ Holding:
The Court ruled that the Attorney General had overstepped his statutory authority.
The Controlled Substances Act did not delegate medical practice decisions to the AG.
Agency interpretations of law must align with legislative intent, and courts must not defer blindly.
💥 Impact:
Reaffirmed limits on executive overreach into areas of state authority and public policy.
Strengthened judicial scrutiny of agency interpretations.
🧑⚖️ 3. Utility Air Regulatory Group (UARG) v. EPA, 573 U.S. 302 (2014)
📌 Facts:
The Environmental Protection Agency (EPA) tried to apply greenhouse gas regulations to small emitters under the Clean Air Act, greatly expanding its reach.
⚖️ Holding:
The Court held that the EPA could not rewrite clear statutory thresholds to fit its climate agenda.
The agency had exceeded its authority by modifying unambiguous terms of the statute.
💥 Impact:
Reaffirmed that agencies must not stretch statutory definitions to expand their regulatory scope.
The Court warned against agencies trying to “bring about an enormous and transformative expansion in regulatory authority” without explicit congressional approval—a key phrase later used in major questions cases.
🧑⚖️ 4. King v. Burwell, 576 U.S. 473 (2015)
📌 Facts:
The IRS interpreted the Affordable Care Act (ACA) to allow tax credits for people in both state and federal exchanges, even though the statute said “established by the State.”
⚖️ Holding:
While the Court upheld the IRS interpretation, it explicitly refused to apply Chevron deference.
The Court said tax credits are a major policy question and that courts, not agencies, should interpret such issues.
💥 Impact:
First major Supreme Court case that declined to apply Chevron to a significant agency interpretation.
Signaled that courts would take the lead in deciding important statutory questions.
🧑⚖️ 5. West Virginia v. EPA, 597 U.S. ___ (2022)
📌 Facts:
The EPA’s Clean Power Plan (Obama-era rule) attempted to shift the nation’s electricity generation away from coal toward cleaner sources—using Section 111(d) of the Clean Air Act.
⚖️ Holding:
The Supreme Court struck down the Clean Power Plan under the major questions doctrine.
It held that EPA lacked clear congressional authorization to make sweeping changes to the nation’s energy policy.
"Transformative" rules require unambiguous legislative approval.
💥 Impact:
Major questions doctrine formalized and elevated.
Severely curtailed agencies' ability to reshape industries or policies under vague statutes.
Became the leading precedent for restricting broad agency actions.
🧑⚖️ 6. National Federation of Independent Business (NFIB) v. OSHA, 595 U.S. ___ (2022)
📌 Facts:
The Occupational Safety and Health Administration (OSHA) issued a rule requiring large employers to ensure vaccination or testing of employees during COVID-19.
⚖️ Holding:
The Court blocked the OSHA rule, finding that the agency lacked authority to issue a public health mandate under its workplace safety statute.
💥 Impact:
Another clear application of the major questions doctrine.
Confirmed that COVID-related emergency measures were not automatically justifiable if they exceeded statutory limits.
Emphasized that regulatory power is not unlimited, even in emergencies.
🧑⚖️ 7. Sackett v. EPA (2023)
📌 Facts:
The EPA applied Clean Water Act protections to the Sackett family’s residential property, arguing it was near protected wetlands.
⚖️ Holding:
The Court limited the definition of "waters of the United States" (WOTUS) and rejected the EPA’s broad interpretation.
It ruled that EPA’s jurisdiction was too expansive and not clearly defined in statute.
💥 Impact:
Significantly curtailed EPA’s authority to regulate private property under environmental laws.
Reaffirmed that agencies cannot assert jurisdiction based on vague policy goals.
🧑⚖️ 8. Loper Bright Enterprises v. Raimondo (2024) — [Chevron Overruled]
📌 Facts:
A group of fishing companies challenged a NOAA rule requiring them to pay for federal observers aboard their vessels, arguing that the statute did not authorize such a financial burden.
⚖️ Holding:
Overruled the Chevron doctrine.
Courts no longer defer to agency interpretations of ambiguous statutes unless Congress clearly delegates that authority.
Agencies must now justify their interpretations with greater clarity and support.
💥 Impact:
Historic narrowing of agency authority.
Ended a 40-year era of judicial deference to agencies (Chevron era).
Agencies must now prove that Congress clearly gave them power to act as they do.
🔍 Summary Table
| Case | Key Issue | Outcome | Impact |
|---|---|---|---|
| FDA v. Brown & Williamson (2000) | FDA regulation of tobacco | Overruled | Agencies need explicit authority |
| Gonzales v. Oregon (2006) | AG blocking state law | Overruled | Limited agency intrusion into state affairs |
| UARG v. EPA (2014) | EPA expanding GHG regulation | Overruled | Agencies can’t alter statutory thresholds |
| King v. Burwell (2015) | IRS ACA tax credits | Upheld | Courts decide major issues, not agencies |
| West Virginia v. EPA (2022) | Clean Power Plan | Overruled | Formalized "major questions" doctrine |
| NFIB v. OSHA (2022) | Vaccine/testing mandate | Overruled | Emergency actions must be within authority |
| Sackett v. EPA (2023) | Wetlands jurisdiction | Overruled | Limited environmental regulatory reach |
| Loper Bright v. Raimondo (2024) | Chevron deference | Overruled | Major rollback of administrative power |
🧩 Key Doctrines Limiting Agency Power
| Doctrine | Meaning |
|---|---|
| Major Questions Doctrine | Agencies cannot decide major economic or political issues without clear Congressional approval. |
| Nondelegation Principle | Congress cannot delegate broad legislative power without intelligible principles. |
| No Chevron Deference (Post-2024) | Courts independently interpret ambiguous statutes without deferring to agencies. |
| Due Process & Separation of Powers | Agencies must not infringe on judicial or legislative roles. |
🏁 Conclusion
The Supreme Court has significantly narrowed the power of federal agencies, particularly:
Restricting expansive interpretations of vague statutes,
Demanding clear congressional authorization for impactful rules,
Ending Chevron deference, which had favored agency discretion for decades.
As a result, federal agencies must now:
Craft rules within tighter legal boundaries,
Provide more explicit statutory justification,
Prepare for increased judicial scrutiny.
These decisions mark a historic shift in the balance of power from the executive back toward Congress and the judiciary.
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