United States Federal Administrative Law encompasses statutes, rules, judicial precedents, and executive orders, that together form administrative laws that define the extent of powers and responsibilities held by administrative agencies of the United States government, including executive departments and independent agencies. Because Congress, the president, and the federal courts have limited resources to address all issues, specialized powers are often delegated to a board, commission, office, or other agency. These administrative agencies oversee and monitor activities in complex areas, such as commercial aviation, medical device manufacturing, and securities markets.
National Cable & Telecommunications Association v. Brand X Internet Services, 545 U.S. 967 (2005), was a United States Supreme Court case in which the court held that decisions by the Federal Communications Commission (FCC) on how to regulate Internet service providers are eligible for Chevron deference, in which the judiciary defers to an administrative agency's expertise under its governing statutes. While the case concerned routine regulatory processes at the FCC and applied to interpretations of the Communications Act of 1934 and Telecommunications Act of 1996, the ruling has become an important precedent on the matter of regulating network neutrality in the United States.
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), was a landmark decision of the United States Supreme Court that set forth the legal test used when U.S. federal courts must defer to a government agency's interpretation of a law or statute. The decision articulated a doctrine known as "Chevron deference". Chevron deference consisted of a two-part test that was deferential to government agencies: first, whether Congress has spoken directly to the precise issue at question, and second, "whether the agency's answer is based on a permissible construction of the statute".
Abbott Laboratories v. Gardner, 387 U.S. 136 (1967), was a case heard before the United States Supreme Court. The Court held that drug companies were not prohibited by the ripeness doctrine from challenging a U.S. Food and Drug Administration (FDA) regulation requiring a prescription drug's generic name to appear on all related printed materials. The government argued that the case was not ripe because the regulation had yet to be enforced. That argument failed as the Court found the issues to be fit for judicial resolution, and that the drug companies would experience substantial hardship if denied a pre-enforcement challenge to the statute. Prosecution for non-compliance was likely, civil and criminal penalties could be imposed, and the drug companies would suffer reputational damage if required to violate the regulation before challenging it in court.
Auer v. Robbins, 519 U.S. 452 (1997), is a United States Supreme Court case that concerns the standard that the Court should apply when it reviews an executive department's interpretation of regulations established under federal legislation. The specific issue was whether sergeants and lieutenants in the St. Louis Police Department should be paid for working overtime. The Fair Labor Standards Act of 1938 established the overtime pay requirement, and the US Department of Labor issued regulations to determine if an employee was covered by the overtime requirement.
United States v. Mead Corp., 533 U.S. 218 (2001), is a case decided by the United States Supreme Court that addressed the issue of when Chevron deference should be applied. In an 8–1 majority decision, the Court determined that Chevron deference applies when Congress delegated authority to the agency generally to make rules carrying the force of law.
Skidmore v. Swift & Co., 323 U.S. 134 (1944), is a United States Supreme Court decision holding that an administrative agency's interpretative rules deserve deference according to their persuasiveness. The court adopted a case-by-case test, the Skidmore deference, which considers the rulings, interpretations, and opinions of the administrator. The Supreme Court reversed and remanded the case for further proceedings.
Christensen v. Harris County, 529 U.S. 576 (2000), is a Supreme Court of the United States case holding that a county's policy of requiring employees to schedule time off to avoid accruing time off was not prohibited by the Fair Labor Standards Act.
Mayo Foundation v. United States, 562 U.S. 44 (2011), is a United States Supreme Court case in which the Court upheld a Treasury Department regulation on the grounds that the courts should defer to government agencies in tax cases in absence of an unreasonable decision on the part of the agency.
King v. Burwell, 576 U.S. 473 (2015), was a 6–3 decision by the Supreme Court of the United States interpreting provisions of the Patient Protection and Affordable Care Act (ACA). The Court's decision upheld, as consistent with the statute, the outlay of premium tax credits to qualifying persons in all states, both those with exchanges established directly by a state, and those otherwise established by the Department of Health and Human Services.
An inter partes review (IPR) is a procedure for challenging the validity of a United States patent before the United States Patent and Trademark Office.
Kisor v. Wilkie, No. 18-15, 588 U.S. ___ (2019), was a US Supreme Court case related to the interpretation by an executive agency of its own ambiguous regulations. The case involved a veteran who had been denied some benefits from the United States Department of Veterans Affairs due to the agency's interpretation of its regulations. The case challenges the "Auer deference" established in the 1997 case Auer v. Robbins, in which the judiciary branch of the government normally defers to an agency's own interpretation of its own regulations in resolving matters of law. Lower courts, including the Federal Appeals Circuit Courts, ruled against the veteran, acknowledging the Auer deference.
Bowen v. Georgetown University Hospital, 488 U.S. 204 (1988), was a case in which the United States Supreme Court held that agencies should not be presumed to have the power to promulgate retroactive rules unless that power is expressly authorized by Congress. Justice Anthony Kennedy wrote for a unanimous court that the Secretary of Health and Human Services had exceeded his rulemaking authority under the Medicare Act in promulgating a wage index rule in 1984 under which he would recoup Medicare reimbursements paid to hospitals, including Georgetown University Hospital, that had been disbursed since 1981 according to the pre-1984 rule. Justice Antonin Scalia concurred in the judgment, writing separately that, in addition to the particular language of the Medicare Act, the Administrative Procedure Act more broadly prohibits retroactive rulemaking because it defines rules as having exclusively future effect, as opposed to adjudicative orders.
Shular v. United States, 589 U.S. ___ (2020), is an opinion of the United States Supreme Court in which the Court held that, under the Armed Career Criminal Act of 1984, the definition of “serious drug offense” only requires that the state offense involve the conduct specified in the statute. Unlike other provisions of the ACCA, it does not require that state courts develop “generic” version of a crime, which describe the elements of the offense as they are commonly understood, and then compare the crime being charged to that generic version to determine whether the crime qualifies under the ACCA for purposes of penalty enhancement. The decision states that offenses defined under the ACCA are "unlikely names for generic offenses," and are therefore unambiguous. This renders the rule of lenity inapplicable.
HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Association, 594 U.S. ___ (2021), was a United States Supreme Court case dealing with exemptions from blending requirements for small refineries set by the Renewable Fuel Standard program. The case dealt with the statutory interpretation of the congressional language for extending the exemption, if this allowed a lapse in the exemption or not. In a 6–3 decision, the Supreme Court ruled that by the majority's interpretation of the law, the congressional law did allow for refineries to seek extensions after their exemption period had lapsed.
Niz-Chavez v. Garland, 593 U.S. 155 (2021), was an immigration decision by the United States Supreme Court. In a 6–3 decision authored by Neil Gorsuch, the Court ruled against the federal government, holding that deportation hearing notices need to be in a single document. Although a highly technical case, the decision received attention for being predicated on the single-letter word a.
The major questions doctrine is a principle of statutory interpretation applied in United States administrative law cases which states that courts will presume that Congress does not delegate to executive agencies issues of major political or economic significance.
Loper Bright Enterprises v. Raimondo, 603 U.S. ___ (2024), 144 S. Ct. 2244, is a landmark decision of the United States Supreme Court in the field of administrative law, the law governing regulatory agencies. Together with its companion case, Relentless, Inc. v. Department of Commerce, it overruled the principle of Chevron deference established in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. (1984), which had directed courts to defer to an agency's reasonable interpretation of an ambiguity in a law that the agency enforces.
Becerra v. San Carlos Apache Tribe, 602 U.S. ___ (2024), was a United States Supreme Court case which determined that the federal government must provide additional funding to cover some third-party administrative costs incurred by Native American tribes that operate their own health-care programs.
Corner Post, Inc. v. Board of Governors of the Federal Reserve System, 603 U.S. ___ (2024), is a United States Supreme Court case about the statute of limitations for judicial review of federal agency rulemaking under the Administrative Procedure Act. The legal question under review was whether a challenge to the validity of a rule must be brought within six years of the rule's issuance—or instead within six years of when the rule first injures the particular plaintiff challenging the rule. The Supreme Court held, by a 6–3 vote, that the statute of limitations does not start running until the particular plaintiff has been harmed by the agency action.
