SCOTUS issues decisions overturning Chevron, limiting SEC adjudication proceedings scope, and more

The U.S. Supreme Court issued its final decisions for the October 2023 term on July 1, 2024. The Supreme Court issued decisions in nine cases related to administrative law during the term. Some of the term’s administrative state-related SCOTUS rulings limited the authority and influence of administrative agencies.

Notably, SCOTUS ruled against judicial deference to federal agency interpretations of ambiguous statutes. SCOTUS also ruled in favor of limiting the scope of in-house agency adjudication and expanding the timeframe to challenge agency actions. Here’s a snapshot of the term’s cases related to administrative law:

• SCOTUS held 7-2 on May 16 in Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America, Limited that Congress statutorily authorized the CFPB to draw money from the Federal Reserve System. The decision held that the agency’s funding structure aligned with the appropriations clause and was constitutional.
• SCOTUS held unanimously on June 13 in Food and Drug Administration (FDA) v. Alliance for Hippocratic Medicine that the plaintiffs did not have standing to challenge the FDA’s regulatory actions related to the approved conditions of mifepristone—a drug used in medication abortions.
• SCOTUS held 6-3 on June 14 in Garland v. Cargill that the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) exceeded its statutory authority in issuing a rule to ban bump stocks. The opinion said ATF did not have authority under the National Firearms Act to issue the rule. The ruling ended the federal bump stock ban.
• SCOTUS held 6-3 on June 27 in Securities and Exchange Commission (SEC) v. Jarkesy that when the SEC seeks civil penalties against defendants for securities fraud, the defendant is entitled to a trial by jury under the Seventh Amendment. The decision changes the SEC’s adjudication and enforcement proceeding structure and prohibits the agency from handling securities fraud cases through its in-house adjudication process.
• SCOTUS decided 5-4 on June 27 in Ohio v. Environmental Protection Agency (EPA) to grant the plaintiff states’ application to temporarily block the EPA’s Good Neighbor rule, pending review in the D.C. Circuit. The agency argued the rule would reduce air pollution from power plants and other facilities in 23 states.
• SCOTUS decided in a per curiam decision on June 27 to dismiss Moyle v. United States as improvidently granted. The case challenged the scope of the Emergency Medical Treatment and Labor Act (EMTALA)—a federal law that requires hospitals to provide necessary stabilizing treatment to pregnant women in medical emergencies. The Biden administration argued emergency abortions should be federally protected under the stabilizing treatment requirement. The court’s decision allows emergency abortions to continue in Idaho and maintains an existing temporary order blocking the state from enforcing its abortion ban. SCOTUS did not rule on the case’s merits and instead returned the case to the lower courts.
• SCOTUS held 6-3 on June 28 in Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. Department of Commerce that federal courts may not defer to an agency’s interpretation of an ambiguous statute. The decision overruled the court’s 1984 decision in Chevron v. Natural Resources Defense Council.
• SCOTUS held 6-3 on July 1 in Corner Post, Inc. v. Board of Governors of the Federal Reserve System that the statute of limitations for filing an Administrative Procedure Act claim begins accruing when the plaintiff is injured by a final agency action, not when the action is promulgated.