Loper Bright Enterprises v. Raimondo (Companion Case: Relentless, Inc. v. Department of Commerce)

The End of Chevron Deference and the Reassertion of Judicial Authority in Statutory Interpretation under the Administrative Procedure Act

Abstract

In Loper Bright Enterprises v. Raimondo (consolidated with Relentless, Inc. v. Department of Commerce), 603 U.S. 369 (2024), the Supreme Court of the United States, by a 6–3 (or 6–2 in one companion) majority, expressly overruled the 40-year-old doctrine of Chevron deference established in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). Authored by Chief Justice Roberts, the opinion held that the Administrative Procedure Act (APA), 5 U.S.C. § 706, requires courts to exercise independent judgment in determining whether an agency has acted within its statutory authority. Courts may no longer defer to an agency’s “reasonable” or “permissible” interpretation of an ambiguous statute that the agency administers. The decision rests on a textualist and originalist reading of the APA and Article III, emphasising the judiciary’s constitutional role as the final arbiter of legal questions. It rejects Chevron’s two-step framework as incompatible with the APA’s command that reviewing courts “decide all relevant questions of law” and “interpret constitutional and statutory provisions.” The ruling is expected to reshape administrative law across environmental, health, labor, financial, and other regulatory domains by shifting interpretive power from agencies to courts, while preserving respect for agency expertise under Skidmore v. Swift & Co., 323 U.S. 134 (1944). This case note analyses the majority’s reasoning, the concurring opinions of Justices Thomas and Gorsuch, and Justice Kagan’s vigorous dissent (joined by Sotomayor, J., and Jackson, J., as to Relentless). It evaluates the doctrinal shift from agency deference to judicial independence, contrasts it with prior erosion of Chevron through the major questions doctrine, and situates the decision within broader debates over separation of powers, textualism, and the administrative state. The note further assesses Loper Bright’s immediate and prospective implications, including its interaction with recent precedents such as West Virginia v. EPA (2022) and Dobbs v. Jackson Women’s Health Organization (2022), as well as partial legislative responses. While the overruling restores a more traditional understanding of judicial review, it raises practical challenges for regulatory certainty and invites continued litigation over statutory boundaries. The analysis concludes that Loper Bright represents a landmark reassertion of judicial authority, doctrinally grounded in the APA and Article III, though its long-term stabilising effect on the administrative state remains uncertain.