The Supreme Court: A Bad Week for the Administrative State …

The Supreme Court: A Bad Week for the Administrative State

• On July 9, 2024, the Supreme Court issued three rulings that collectively reduce the power of federal administrative agencies.

• In Loper Bright Enterprises v. Raimondo, the Court overturned the Chevron Doctrine, which previously required courts to defer to agency interpretations of ambiguous statutes, stating that courts must now independently determine the meaning of statutes.

• The Court ruled that the Administrative Procedure Act (APA) does not permit deference to agency interpretations, affirming that courts are responsible for interpreting statutory provisions.

• In SEC v. Jarkesy, the Court decided that defendants facing civil penalties for securities fraud have the right to a jury trial under the Seventh Amendment, preventing the SEC from handling such cases through its own administrative processes.

• The Court clarified that the Seventh Amendment guarantees a jury trial in legal claims, especially when punitive monetary damages are sought.

• In Corner Post v. Board of Governors of the Federal Reserve System, the Court established that the statute of limitations for APA claims starts when a plaintiff is harmed by final agency action, not when the rule is finalized, broadening the scope for challenging federal regulators.

• Justice Kavanaugh highlighted that courts can invalidate improper agency rules more broadly, which could significantly impact administrative law.

• The implications of these rulings affect all federal agencies, as the elimination of the Chevron Doctrine changes how agencies interpret ambiguous statutes, while the Jarkesy and Corner Post decisions apply to various regulatory bodies beyond the SEC.

• Overall, these decisions mark a significant setback for the administrative state, curtailing the power and interpretive authority of federal agencies.