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McLaughlin Chiropractic Associates v. McKesson Corp.

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Supreme Court of the United States
McLaughlin Chiropractic Associates v. McKesson Corp.
Term: 2024
Important Dates
Argued: January 21, 2025
Decided: June 21, 2025
Outcome
reversed
Vote
6-3
Majority
Brett Kavanaugh • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch • Amy Coney Barrett
Dissenting
Elena Kagan • Sonia Sotomayor • Ketanji Brown Jackson

McLaughlin Chiropractic Associates v. McKesson Corp. is a case concerning whether the Hobbs Act requires a district court to accept the Federal Communications Commission's (FCC) legal interpretation of the Telephone Consumer Protection Act (TCPA).

The case was decided by the Supreme Court of the United States on June 21, 2025.[1] The case was argued before the court on January 21, 2025, during the court's October 2024-2025 term.

In a 6–3 opinion, the Court reversed the judgment of the United States Court of Appeals for the Ninth Circuit. The Court held that the Hobbs Act does not prevent district courts from considering whether an agency's interpretation of a statute is correct in the course of resolving private disputes. Writing for the majority, Chief Justice John Roberts explained that nothing in the Hobbs Act displaces the traditional authority of federal district courts to interpret federal law. The decision limits the binding effect of agency interpretations outside of direct Hobbs Act challenges, reinforcing the role of Article III courts in independently interpreting statutes.[1]

HIGHLIGHTS
  • The issue: The case concerned whether the Hobbs Act requires a district court to accept the Federal Communications Commission's (FCC) legal interpretation of the Telephone Consumer Protection Act. Click here to learn more about the case's background.
  • The questions presented: "Whether the Hobbs Act required the district court in this case to accept the FCC's legal interpretation of the Telephone Consumer Protection Act."[2]
  • The outcome: In a 6–3 opinion, the Court reversed the judgment of the United States Court of Appeals for the Ninth Circuit.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit. To review the lower court's opinion, click here.

    Why it matters: The case significantly limits the binding force of administrative agency interpretations in private litigation outside of direct challenges brought under the Hobbs Act. By reaffirming the authority of Article III courts to independently interpret federal statutes, the decision strengthens the judiciary’s role in statutory interpretation and signals skepticism toward doctrines that give agencies preemptive interpretive control. It also underscores the Court's ongoing trend of narrowing judicial deference to administrative agencies, further curbing agency power in line with broader challenges to the modern administrative state.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: McLaughlin Chiropractic Associates, Inc.
      • Legal counsel: Matthew W.H. Wessler (Gupta Wessler LLP)
    • Respondent: McKesson Corporation, et al.
      • Legal counsel: Deanne Elizabeth Maynard (Morrison & Foerster LLP)

    The following summary of the case was published by Oyez[4]

    “ True Health Chiropractic, Inc. and McLaughlin Chiropractic Associates, Inc. filed a class action lawsuit against McKesson Corporation and McKesson Technologies, Inc. The plaintiffs alleged that the defendants violated the Telephone Consumer Protection Act (TCPA) by sending unsolicited advertisements via fax. They claimed they neither invited nor gave permission to receive these faxes, and even if there was permission or an established business relationship, the faxes lacked the required opt-out notice.


    The district court initially granted summary judgment to the plaintiffs on McKesson's consent defenses. The court also decertified the proposed class and denied treble damages to the plaintiffs. McKesson appealed the summary judgment decision on their consent defenses. The plaintiffs cross-appealed the class decertification and denial of treble damages. The U.S. Court of Appeals for the Ninth Circuit reviewed the summary judgment de novo, the decertification order for abuse of discretion, and the denial of treble damages for abuse of discretion, ultimately affirming all of the district court’s decisions. [5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether the Hobbs Act required the district court in this case to accept the FCC's legal interpretation of the Telephone Consumer Protection Act.[5] ”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 6–3 opinion, the Court reversed the judgment of the United States Court of Appeals for the Ninth Circuit, holding that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. Justice Brett Kavanaugh delivered the opinion of the Court. [1]


    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    “

    The Hobbs Act does not preclude district courts in enforcement proceedings from independently assessing whether an agency’s interpretation of the relevant statute is correct. Here, therefore, the District Court should interpret the TCPA under ordinary principles of statutory interpretation, affording appropriate respect to the agency’s interpretation. [5]

    		”
    —Justice Brett Kavanaugh

    Dissenting opinion

    Justice Elena Kagan filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson.

    In her dissent, Justice Kagan wrote:[1]

    “

    The Hobbs Act’s text provides the answer. By its terms, the Hobbs Act gives courts of appeals exclusive authority to 'determine the validity' of specified agency actions. 'Exclusive,' of course, means courts of appeals alone, not district courts. [5]

    		”
    —Justice Elena Kagan

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Supreme Court of the United States, "McLaughlin Chiropractic Associates v. McKesson Corp.", June 20, 2025
    2. ↑ 2.0 2.1 Supreme Court of the United States, "23-1226 MCLAUGHLIN CHIROPRACTIC ASSOCIATES V. MCKESSON CORP. QP", October 4, 2024
    3. ↑ Supreme Court of the United States, "No. 23-1226," accessed November 25, 2024
    4. ↑ Oyez, "McLaughlin Chiropractic Associates, Inc. v. McKesson Corporation," accessed November 25, 2024
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ United States Court of Appeals for the Ninth Circuit, True Health Chiropractic, Inc. v. McKesson Corp., decided October 25, 2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 21, 2025
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 21, 2025
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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