MPBA 3RD QTR MAGAZINE 2024 FOR WEB

The Cavalry Group Report: Supreme Court Decision to Overturn Chevron Deference: A Boon for Animal-Related Businesses By Mindy Patterson

The recent Supreme Court decision to overturn Chevron Deference signals a fundamental change in the balance of power between the judiciary and federal agencies. The Court’s ruling underscores the principle that it is ultimately the judiciary’s role to interpret the law, rather than deferring to administrative agencies. In its decision, the Supreme Court emphasized the need for clear statutory language and cautioned against allowing agencies to fill in the gaps of ambiguous legislation without judicial oversight. This move aims to restore a more balanced approach to regulatory interpretation, ensuring that agencies and their unelected bureaucrats adhere more closely to the letter of the law as written by Congress. Accordingly, the overturning of Chevron Deference is poised to have a profound impact on animal-related businesses licensed by the USDA under APHIS’ Animal

Chevron Deference, established by the 1984 Supreme Court case Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., required courts to defer to an agency’s interpretation of an ambiguous statute it administers, as long as the interpretation is reasonable. This doctrine has significantly empowered federal agencies, enabling them to enact and enforce regulations with considerable discretion. While Chevron Deference was intended to ensure that government agencies, with their supposed “specialized expertise,” could effectively implement complex statutory schemes, it has also led to concerns about unchecked regulatory power and inconsistent application of laws. Businesses, including those in the animal enterprise sector, have often found themselves at the mercy of fluctuating and unpredictable regulatory interpretations.

In a landmark decision, the Supreme Court has overturned the Chevron Deference, a judicial doctrine that has long given federal agencies significant latitude in interpreting ambiguous statutes. This ruling marks a significant shift in administrative law and promises to have far-reaching implications for various sectors, including animal-related businesses licensed by the USDA under the Animal and Plant Health Inspection Service’s (APHIS) Animal Care division. For years, these businesses have faced stringent and often heavyhanded enforcement actions from APHIS, frequently finding themselves written up for violations not explicitly outlined in the Animal Welfare Act (AWA) or the Horse Protection Act (HPA). The overturning of Chevron Deference offers a glimmer of hope for these enterprises, potentially ushering in an era of fairer and more predictable regulatory oversight.

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