Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)
Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.
467 U.S. 837 (1984)
Facts: The Clean Air Act Amendments of 1977 required some of the states which have not yet conformed to the national air quality standards of the EPA to comply with the set standards pursuant to the unamended Clean Air Act. The EPA enacted regulations which interpreted the term “stationary source” to permit the other states to treat all of the pollution-emitting devices coming from similar industrial group to be included in the same bubble (Case Note Legal Briefs, 2010). As a result, the EPA created a regulation which allows the States to embrace a new definition of the term “stationary source” which was to be applied in all plants. Such definition enabled an existing plant which is comprised of various pollution-emitting devices to install and adjust even a single piece of equipment devoid of the permit in the event that the overall plant emissions were not amplified by the modification of the “bubble” perception (Case Note Legal Briefs, 2010). As part of its response, respondent NRDC, the respondents in this case filed a petition for review before the Court of Appeals for the District of Columbia Circuit. The Court of Appeals ruled in favor of the respondents and dismissed the regulation. The amendments to the Clean Air Act proved to be complicated, extensive and detailed. Such amendments did not perturb the previous definition of the term “stationary source. Instead, it added a different definition for the phrase “major stationary source.” Tracing back the records of the amendments, it was revealed that the history of amendments did not include a particular comment on the “bubble concept”. Nor does it resolve the issue on whether a “stationary source” was acceptable pursuant to the permit program which was intended to improve the air quality.
Procedural Posture: Based on the ruling made by the Court of Appeals, it was shown that the pertinent portion of the amended Clean Air Act did not expressly give a clear description of what the Legislative Department projected to be the “stationary source” to which the permit program is to be applied. It bears stressing that the legislative history did not rule upon this exact issue. Hence, the appellant raised the issue on appeal via a petition for review before the Supreme Court to set aside the ruling of both the Court of Appeals for the District of Columbia Circuit, and the Court of Appeals (Case Note Legal Briefs, 2010).
Issue: The issue in this case is whether or not the ruling of the EPA’s construction of a limited statute can be subject to judicial review for the determination of whether it is based on a reasonable construction of a statutory term even there is absence of clear legislative intent.
Ruling: The Supreme Court held in the affirmative by stating that judicial review of an agency’s construction (EPA) of a statute should be restricted to the determination of whether it is an acceptable construction of the statute in the absence of a clear legislative intent. Pursuant to the legislative history behind the EPA regulations, there was no clear-cut comment on the permissibility of the “bubble concept”; instead it contained a discussion of the accommodation of the economic interest in capital improvement and environmental issues (Case Note Legal Briefs, 2010). Hence, the court cannot substitute its own statutory construction for an acceptable interpretation given by an agency such as the EPA. It was revealed that EPA has consistently interpreted the term “statutory source” in a flexible manner. It was only the Court of Appeals which given a static definition of the term “statutory source”. In effect, the regulations issued by the EPA symbolize a reasonable accommodation among congressionally defined benefits. In addition, it was not EPA but the Court of Appeals which interpreted the statute rigidly in 1980 to order a plant-wide meaning for the factories that are constructed to uphold clean air, and to disallow such interpretation for programs that are created to enhance the air quality.
Judgment: The Supreme Court reversed the ruling of the Court of Appeals since there was a clear manifestation that there was a basic legal oversight on the part of the Court of Appeals when it assumed a fixed definition of the term “stationary source”. Furthermore, the Court of Appeals cannot adopt a static definition when even the Legislative department did not provide such definition or interpretation. In fact, tracing back the records of the amendments, it was revealed that the history of amendments does not contain a particular comment on the “bubble concept”. Therefore, the EPA’s construction of a statute should be restricted to the determination of whether it is an acceptable construction of the statute in the absence of a clear legislative intent.
Rationale: The ruling of the Supreme Court in this case of Chevron became a celebrated case which had advocated the allowance given to agencies’ reverence for their reasonable and independent policy-making resolutions (Case Note Legal Briefs, 2010). The primary step is for the determination of legislative intent in the interpretation of a statute. In the event that Congress has provided a clear and definite guidance as to how to interpret a statutory term, the agency is not given its own discretion for its own interpretation of the statute. But rather, it should adopt the regulations the regulations that mandate the express intention of Congress.
Comments: When a court reviews the construction of an agency regarding the definition of a particular statute under its administration, the court has to resolve two questions namely: First, is to determine whether the Legislative department has given its comment to the exact question that is put in issue. If the intention of Congress has been expressed clearly in definite terms, then there is no need for the court to resolve the matter but to follow the legislative intent. In the event that the court finds that Congress has not addressed the exact question at issue, it cannot provide its own statutory construction by imposing a rigid interpretation. In the absence of a definite administrative interpretation or when Congress is silent with regard to a particular issue, what the court has to do is to determine whether the agency has given an answer on the basis of an acceptable construction of the statute concerning a specific issue.
Bibliography:
Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)
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