On June 28, 2024, the United States Supreme Court issued a decision in Loper Bright Enterprises et al. v. Raimondo (Loper Bright) which overturned the long-standing precedent of Chevron USA Inc. v. NRDC. The Chevron case established the so-called Chevron Doctrine which stated that judicial deference should be afforded to federal agency determinations in interpreting statutes where legislation may be ambiguous or subject to interpretation.
With the 6-3 opinion, the Court shifted authority for interpreting legislation from federal agencies to the judiciary. The Supreme Court decided that courts are best positioned to interpret whether government agencies have statutory authority when the agency's actions extend beyond the language of the legislative provisions, even in agency-specific areas.
Review the details here.
ADP® routinely monitors court proceedings and agency determinations impacting our operations and those of our clients and we will continue to do so following the Loper Bright ruling, including with respect to any cases currently on Federal Court dockets which may have relied on the Chevron Doctrine.
Administrative law areas of potential focus based on the Loper Bright ruling include regulations issued by agencies such as the DOL, National Labor Relations Board, Equal Employment Opportunity Commission, and the FTC, among others on topics such as wage and hour, fiduciary rules, discrimination and harassment, labor relations, and non-compete agreements.
ADP will continue to monitor developments related to this decision.