Constitution and the Administrative State - Case Analysis

This case analysis deals with the landmark judgment delivered by the U.S. Supreme Court in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. 467 U.S. 837 (1984) which presided over the question of limiting administrative powers through judicial interpretation of empowering statues. The case was brought before the Court by the petitioner the Chevron Corporation (the plaintiff) against the Environmental Protection Committee (the defendant).

Running head: CONSTITUTION AND THE ADMINISTRATIVE STATE
CONSTITUTION AND THE ADMINISTRATIVE STATE
Name of the Student
Name of the University
Author Note

1CONSTITUTION AND THE ADMINISTRATIVE STATE
Introduction
The doctrine of Separation of powers dictates that the powers of government agencies
should be ideally limited and not overlapping with each other. This is to eliminate all forms of
ambiguity in administrative process. Thus the powers and functions of each wing of the
government are well-defined and are separate from each other. The following paragraphs will
deal with a case analysis based on the land mark judgment delivered by the U.S. Supreme Court
in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. 467 U.S. 837 (1984) which
presided over the question of limiting administrative powers through judicial interpretation of
empowering statues (Gluck, 2014).
Facts and Parties
The case was brought before the Court by the petitioner the Chevron Corporation (the
plaintiff) against the Environmental Protection Committee (the defendant) (Rosenbloom, 2018).
This related to an amendment to the Clean Air Act, 1963 which was amended in 1977 by the
congress.
Issues
The issue to be determined by the court was the interpretation of provisions of the
amendment in order to confer certain powers on the regulatory authority. The Company wanted a
different kind of interpretation through a more liberal construction rule whereas the defendant
contended that the powers conferred under the act would have to be given a more literal
construction so as to provide them with adequate powers under the act (Beermann, 2014).

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Judgment
The court held that in such regulatory statutes if the congress has failed to provide a clear
intent of the provision then it would have to be interpreted as literally as possible in light of the
unambiguous terms. However, if the intent of the same is not clarified then the rule would have
to be interpreted in the way that the administrative agency interprets it as long as the same is a
reasonable and permissible by due process of law (Adler, 2016). The rationale behind such a
finding of the court is that the enforcement regulatory authority would use the powers conferred
to it to ensure that the provisions are utilized in the most prudent way possible.
Relevance
The defense laid down by the court in Chevron U.S.A., Inc. v. Natural Resources
Defense Council, Inc. 467 U.S. 837 (1984) has also been called the Chevron defense and has
been applied in numerous cases over the years. This defense thus ensured that where the
congress has not specified the purpose of a particular provision in an act then the same would be
interpreted by the Administrative agency in the way that is most suitable for their contentions
(Merrill, 2014). It has thus been contended over the years that this defense provides an ambit for
arbitrary and discretionary interpretation of these rules that are solely based on the
Administrative authority’s construction of the same.
Prospective effect and present viability
Since the time of the judgment in Chevron U.S.A., Inc. v. Natural Resources Defense
Council, Inc. 467 U.S. 837 (1984) it has been cited in various disputes and has been sufficiently
given effect to in the same. However through the years various jurists have submitted that the

3CONSTITUTION AND THE ADMINISTRATIVE STATE
Chevron Defense affords discretionary powers to the Administrative authorities and does not
concur with and cannot be applied to any other individual or agency (Hammond, 2014). In all
other cases the provisions of statutes are literally interpreted with the help of supporting
precedents. In the case of King v. Burwell 576 U.S. (2015) it was held by the Supreme Court that
the Chevron Defense cannot be applied to matters that pertain significantly to the economy or
politics of the realm.
Conclusion
This case had provided a concrete defense to Administrative authorities in terms of the
powers conferred under regulatory acts interpreted in light of their convenience. However the
same cannot be condoned for all forms of disputes.

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Reference list
Adler, J. H. (2016). Restoring Chevron's Domain. Mo. L. Rev., 81, 983.
Beermann, J. M. (2014). Chevron at the Roberts Court: Still Failing After All These
Years. Fordham L. Rev., 83, 731.
Gluck, A. R. (2014). What 30 Years of Chevron Teach Us About the Rest of Statutory
Interpretation. Fordham L. Rev., 83, 607.
Hammond, E. (2014). Chevron's Generality Principles. Fordham L. Rev., 83, 655.
Merrill, T. W. (2014). The story of Chevron: the making of an accidental
landmark. Admin. L. Rev., 66, 253.
Rosenbloom, D. H. (2018). Administrative law for public managers. Routledge.