How vague statutory language enabled the Biden administration’s CHIPS Act overreach, and what Congress must do next

My latest op-ed in the Washington Reporter uses FOIA docs from the CHIPS Act implementation to demonstrate how ambiguous laws empower unelected bureaucrats and undermine democratic accountability: When Congress rejected sweeping child care subsidies in the Inflation Reduction Act, the Biden administration’s Commerce Secretary Gina Raimondo reportedly told her staff, “if Congress wasn’t going to do what they…

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Eight Circuit Applies Loper Bright in FCC Quadrennial Review Dispute 

On July 23rd, in Zimmer Radio of Mid-Missouri v. FCC, the Eighth Circuit applied the Supreme Court’s decision in Loper Bright to a dispute over the FCC’s quadrennial review of its media ownership rules in a way that highlights a few key themes in Loper Bright statutory interpretation cases.  Background on the FCC Order Under Section…

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Loper Bright Mentioned in Trump Tariff Case at Federal Circuit Oral Argument

Here’s how the Wall Street Journal Editorial Page described the exchange: Mr. Nixon’s tariffs for the most part also didn’t exceed the tariff “schedule that had already been enacted,” said another judge. Mr. Trump’s do. Mr. Shumate’s fall-back was that IEEPA was meant to be interpreted “very broadly.” But “is that really how we interpret…

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SCOTUSblog Term Review on Deference

At SCOTUSblog, Abbe R. Gluck writes about Kennedy v. Braidwood Management, and ” the broader question of how the court will grapple with questions of expertise in the wake of its 2024 decision overruling Chevron v. Natural Resources Defense Council, the key agency-deference case of the modern era.” Finally, for good measure, the opinion concludes with a…

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Bloomberg Law on Appeals Courts and Loper

Bloomberg Law’s Robert Iafolla writes about how “circuit courts have started going in different directions on the level of deference judges should grant agencies.” Federal appeals courts are still figuring out how much weight to give to agencies’ views of their legal authority, a year after the US Supreme Court said judges must interpret relevant…

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New Paper Argues for “Gray Doctrine” of Implicit Delegation

Harvard Law School’s Matthew Stephenson recently published “The Gray Area: Finding Implicit Delegation to Agencies After Loper Bright.” From the abstract: This Article argues that the canonical pre-Chevron cases Gray v. Powell and NLRB v. Hearst Publications, together with their antecedents and progeny, provide a useful framework for distinguishing those interpretive questions on which courts ought to find implicit…

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