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The correct answer was stationary source.
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| Chevron v. Natural Resources Defense Council | |
| Reference: 467 U.S. 837 | |
| Term: 1983 | |
| Important Dates | |
| Argued: February 29, 1984 Decided: June 25, 1984 | |
| Outcome | |
| D.C. Circuit reversed | |
| Majority | |
| Chief Justice Warren Burger • Harry Blackmun • William Brennan • Lewis Powell • John Paul Stevens • Byron White | |
| Concurring | |
| None | |
| Dissenting | |
| None | |
Chevron U.S.A. v. Natural Resources Defense Council was a case decided on June 25, 1984, by the United States Supreme Court. The case is famous for establishing the extent to which a federal court, in reviewing a federal government agency's action, should defer to the agency’s construction of a statute that the agency has been delegated to administer. This principle is commonly known as Chevron deference.[1]
In brief: The Environmental Protection Agency issued a regulation defining the statutory term stationary source for the purpose of implementing the 1977 amendments to the Clean Air Act. Under the regulation, the agency allowed states to treat all pollution-emitting devices within the same industrial grouping as though they were encased within a single bubble or stationary source. The National Resources Defense Council sued the EPA and several companies in federal court, and the D.C. Circuit Court of Appeals set aside the agency's regulation. The Supreme Court reversed this decision in favor of the agency, holding that the EPA's regulation was a permissible definition of the statutory term stationary source.
Definition of statutory source
Justice Stevens presented a lengthy history of the term stationary source, reviewing the relevant statutes, amendments, legislative history, and regulatory language. Upon this review, the court agreed with the circuit court that, in part, the court was not persuaded that parsing of general terms in the text of the statute revealed an actual intent of Congress and that the legislative history was unilluminating on the precise issue in question. Nevertheless, the court found a consistency throughout the examination of the sources presented.[2]
| “ |
...the agency primarily responsible for administering this important legislation has consistently interpreted it flexibly - not in a sterile textual vacuum, but in the context of implementing policy decisions in a technical and complex arena. The fact that the agency has from time to time changed its interpretation ... does not, as respondents argue, lead us to conclude that no deference should be accorded the agency's interpretation of the statute. An initial agency interpretation is not instantly carved in stone. On the contrary, the agency, to engage in informed rulemaking, must consider varying interpretations and the wisdom of its policy on a continuing basis. Moreover, the fact that the agency has adopted different definitions in different contexts adds force to the argument that the definition itself is flexible, particularly since Congress has never indicated any disapproval of a flexible reading of the statute. Significantly, it was not the agency in 1980, but rather the Court of Appeals that read the statute inflexibly to command a plantwide definition for programs designed to maintain clean air and to forbid such a definition for programs designed to improve air quality. The distinction the court drew may well be a sensible one, but our labored review of the problem has surely disclosed that it is not a distinction that Congress ever articulated itself, or one that the EPA found in the statute before the courts began to review the legislative work product.[3] |
” |
See also
- Chevron deference (doctrine)
- Deference (administrative state)
- Auer v. Robbins
- Supreme Court of the United States
- History of the Supreme Court
Footnotes
- ↑ U.S. Department of Justice, "Chevron, U.S.A. v. Natural Res. Def. Council," accessed July 15, 2016
- ↑ Cite error: Invalid
<ref>tag; no text was provided for refs namedopinion - ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
