List of court cases relevant to agency dynamics

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The following table contains major state and federal court cases related to agency dynamics.

Cases relevant to agency dynamics
Case Court Year Impact
Crowell v. Benson U.S. Supreme Court 1932 In a ruling that helped define the relationship between agencies and federal courts prior to the Administrative Procedure Act, the court upheld the constitutionality of agency adjudication but required courts to review factual questions related to agency jurisdiction or constitutional restrictions de novo.
Humphrey's Executor v. United States U.S. Supreme Court 1935 The court described independent federal agencies as quasi-legislative and quasi-judicial entities and affirmed that their commissioners have protections against removal by the president.
United States v. Florida East Coast Railway Co. U.S. Supreme Court 1973 The court held that formal rulemaking procedures are only required when a statute calls for a hearing "on the record."
National Labor Relations Board v. Sears, Roebuck & Co. U.S. Supreme Court 1975 The ruling clarified the scope of the exemptions to the Freedom of Information Act. The decision clarified whether certain types of agency memoranda are subject to the Freedom of Information Act.
Butz v. Economou U.S. Supreme Court 1978 The court held that federal administrative officials performing discretionary functions are limited to qualified immunity while federal administrative officials who participate in adjudication proceedings are entitled to absolute immunity.
Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council U.S. Supreme Court 1978 The court held that courts cannot impose additional procedural requirements on agencies and cannot invalidate agency actions simply because they do not like the final result.
Federal Trade Commission (FTC) v. Standard Oil Company of California U.S. Supreme Court 1980 The ruling helped define the scope of final agency actions subject to judicial review.
Schweiker v. McClure U.S. Supreme Court 1982 The ruling allowed privately employed hearing officers to serve as administrative judges in adjudication.
Baltimore Gas & Electric Co. v. Natural Resources Defense Council, Inc. U.S. Supreme Court 1983 The ruling endorsed a version of hard look review that required agencies to consider all relevant facts, as defined by law, before making their regulatory decisions.
Immigration and Naturalization Service (INS) v. Chadha U.S. Supreme Court 1983 The court held that the legislative veto, which gave Congress oversight powers over specific agency rulemaking actions in some cases, was unconstitutional.
Heckler v. Chaney U.S. Supreme Court 1985 The ruling established a presumption against review of agency inaction that limited the scope of judicial review. At the same time, the court held that agency inaction was subject to judicial review if the agency's inaction amounted to an abdication of statutory responsibilities.
Appalachian Power Company v. Environmental Protection Agency U.S. Supreme Court 2000 The court ordered the removal of a guidance document issued by the Environmental Protection Agency because the document instituted a regulatory change without following the required rulemaking procedures.
General Electric Company v. Environmental Protection Agency United States Court of Appeals for the District of Columbia Circuit 2002 The D.C. Circuit affirmed that new agency regulations must be promulgated through the proper rulemaking procedures and cannot be implemented through guidance documents.
Massachusetts v. Environmental Protection Agency U.S. Supreme Court 2007 The Supreme Court ruled that a federal agency does not have the discretion to cite policy preferences as a reason for refusing to regulate certain issues under its purview.
FCC v. Fox Television Stations Inc. U.S. Supreme Court 2009 The court held that when agencies change prior policy, there is no heightened standard of review required by law.
Business Roundtable v. SEC U.S. Supreme Court 2011 The court held that the agency did not provide adequate cost-benefit analysis when it studied a rule's potential economic impact. Without that analysis, the court held that the agency acted in an arbitrary-or-capricious manner and vacated the rule.
Iowa League of Cities v. Environmental Protection Agency United States Court of Appeals for the 8th Circuit 2013 The Eighth Circuit affirmed that new agency regulations must be promulgated through the rulemaking procedures of the APA and cannot be implemented through guidance documents.
Perez v. Mortgage Bankers Association U.S. Supreme Court 2015 The court clarified that federal agencies must engage in the rulemaking process in order to make changes to regulations that carry the force of law.
Azar v. Allina Health Services U.S. Supreme Court 2019 The court declined to draw a bright line between substantive and interpretive rules in general, but it did clarify that both substantive and interpretive rules promulgated under the Medicare Act must follow notice-and-comment rulemaking procedures.
Seila Law v. Consumer Financial Protection Bureau U.S. Supreme Court 2020 The court held that restrictions on the president's ability to remove single heads of independent federal agencies violated separation of powers principles by limiting executive control of such agencies.
Salinas v. United States Railroad Retirement Board U.S. Supreme Court 2021 The decision allows courts to review agency decisions not to reopen cases, which expanded the definition of final agency actions open to judicial review.
FCC v. Prometheus Radio Project U.S. Supreme Court 2021 The court held that federal agencies can pass the arbitrary-or-capricious test even if they do not have to have perfect empirical data before they make reasonable decisions.
Loper Bright Enterprises v. Raimondo U.S. Supreme Court 2024 The court held that federal courts should not defer to agency interpretations of ambiguous statutory language, overturning Chevron v. Natural Resources Defense Council.

See also

Footnotes

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The Administrative State
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Laws
Administrative Procedure Act • Antiquities Act • Civil Service Reform Act • Clayton Antitrust Act • Communications Act of 1934 • Congressional Review Act • Electronic Freedom of Information Act • Federal Food, Drug, and Cosmetic Act of 1938 • Federal Housekeeping Statute • Federal Reserve Act • Federal Trade Commission Act of 1914 • Freedom of Information Act • Government in the Sunshine Act • Independent Offices Appropriations Act of 1952 • Information Quality Act • Interstate Commerce Act • National Labor Relations Act • Paperwork Reduction Act • Pendleton Act • Privacy Act of 1974 • Regulatory Flexibility Act • REINS Act • REINS Act (Wisconsin) • Securities Act of 1933 • Securities Exchange Act of 1934 • Sherman Antitrust Act • Small Business Regulatory Enforcement Fairness Act • Truth in Regulating Act • Unfunded Mandates Reform Act
Cases
Abbott Laboratories v. Gardner • A.L.A. Schechter Poultry Corp. v. United States • Association of Data Processing Service Organizations v. Camp • Auer v. Robbins • Chevron v. Natural Resources Defense Council • Citizens to Preserve Overton Park v. Volpe • Federal Trade Commission (FTC) v. Standard Oil Company of California • Field v. Clark • Food and Drug Administration v. Brown and Williamson Tobacco Corporation • Humphrey's Executor v. United States • Immigration and Naturalization Service (INS) v. Chadha • J.W. Hampton Jr. & Company v. United States • Lucia v. SEC • Marshall v. Barlow's • Massachusetts v. Environmental Protection Agency • Mistretta v. United States • National Federation of Independent Business (NFIB) v. Sebelius • National Labor Relations Board v. Noel Canning Company • National Labor Relations Board v. Sears, Roebuck & Co. • Panama Refining Co. v. Ryan • Securities and Exchange Commission v. Chenery Corporation • Skidmore v. Swift & Co. • United States v. Lopez • United States v. Western Pacific Railroad Co. • Universal Camera Corporation v. National Labor Relations Board • Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council • Wayman v. Southard • Weyerhaeuser Company v. United States Fish and Wildlife Service • Whitman v. American Trucking Associations • Wickard v. Filburn • Wiener v. United States
Terms
Adjudication (administrative state) • Administrative judge • Administrative law • Administrative law judge • Administrative state • Arbitrary-or-capricious test • Auer deference • Barrier to entry • Bootleggers and Baptists • Chevron deference (doctrine) • Civil servant • Civil service • Code of Federal Regulations • Codify (administrative state) • Comment period • Compliance costs • Congressional Record • Coordination (administrative state) • Deference (administrative state) • Direct and indirect costs (administrative state) • Enabling statute • Ex parte communication (administrative state) • Executive agency • Federal law • Federal Register • Federalism • Final rule • Formal rulemaking • Formalism (law) • Functionalism (law) • Guidance (administrative state) • Hybrid rulemaking • Incorporation by reference • Independent federal agency • Informal rulemaking • Joint resolution of disapproval (administrative state) • Major rule • Negotiated rulemaking • Nondelegation doctrine • OIRA prompt letter • Organic statute • Pragmatism (law) • Precautionary principle • Promulgate • Proposed rule • Publication rulemaking • Regulatory budget • Regulatory capture • Regulatory dark matter • Regulatory impact analysis • Regulatory policy officer • Regulatory reform officer • Regulatory review • Rent seeking • Retrospective regulatory review • Risk assessment (administrative state) • Rulemaking • Separation of powers • Significant regulatory action • Skidmore deference • Statutory authority • Substantive law and procedural law • Sue and settle • Sunset provision • Unified Agenda of Federal Regulatory and Deregulatory Actions • United States Code • United States Statutes at Large
Bibliography
Agencies
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