Friday, November 15, 2013

Chevron U.S.A. Inc. v. Natural Resources Defense Council case brief

Chevron U.S.A. Inc. v. Natural Resources Defense Council case brief summary
467 U.S. 837 (1984)

CASE SYNOPSIS
Petitioner sought review of a judgment from the United States Court of Appeals for the District of Columbia Circuit, which set aside a regulation. Petitioner contended that the Environmental Protection Agency regulation, implementing permit requirements for nonattainment states pursuant to the Clean Air Act Amendments of 1977, 42 U.S.C.S. § 7502(b)(6), was a reasonable interpretation of the term "stationary source."

CASE FACTS
Petitioner argued that the Environmental Protection Agency (EPA) regulation, implementing permit requirements for nonattainment states pursuant to the Clean Air Act Amendments of 1977 (Act), 42 U.S.C.S. § 7502(b)(6), permitting states to treat all of the pollution-emitting devices within the same industrial groupings as though they were encased within a single bubble, was a reasonable construction of the statutory term stationary source.

DISCUSSION
On appeal, the judgment below was reversed. In support of its ruling, the Supreme Court held that if a statute was silent or ambiguous with respect to the specific issue, the question for a court was whether the agency's action was based on a permissible construction of the statute. Further, considerable weight was to be accorded to an agency's construction of a statutory scheme. The Court noted that while the legislative history of the statute was silent on the instant issue, it did reveal that the EPA's interpretation was fully consistent with one of the two principal goals of the statute -- namely, allowance of reasonable economic growth. Accordingly, the EPA's interpretation was entitled to deference.

CONCLUSION

The Court reversed the judgment because the EPA's interpretation of the statute was a permissible construction and entitled to deference, where the legislative history of the statute was silent as to the instant issue.

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