Case: 25-7831, 03/10/2026, DktEntry: 81.1, Page 22 of 43
rules of statutory interpretation when deciding federal law’s “preemptive effect.” Id. The Supreme Court recently clarified one relevant rule of statutory interpretation. Specifically, in Loper Bright , the Court overruled the doc- trine of Chevron deference, under which the judiciary sometimes deferred to federal agencies’ interpretation of federal statutes. 603 U.S. at 377– 80, 412–13. It is the role of judges, Loper Bright explained, “to determine the best reading of” federal statutes. Id. at 400. This remains true in cases presenting “technical statutory questions.” Id. at 402. Federal agencies, the decision went on, have “no special competence” when it comes to interpreting “the scope of” their “own power.” Id. at 400–01. If anything, “abdication in favor of [an] agency is least appropriate” in such scenarios. Id. at 401. The Supreme Court thus held that judges “must exercise their independent judgment in deciding whether” a matter fits within an agency’s “statutory authority.” Id. at 412. For preemption purposes, Loper Bright built on top of an existing foun- dation. Even during the Chevron era, the Supreme Court stressed that “agencies have no special authority to pronounce on pre-emption absent delegation by Congress.” Wyeth , 555 U.S. at 577. Courts, therefore, were
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