Third Circuit Upholds PBGC Relief-Fund Asset Regulations Under Loper Bright 

Earlier this month, the Third Circuit released its decision in In re Yellow Corp., a case that started as a high-stakes bankruptcy dispute and ended up involving a challenge to the Pension Benefit Guaranty Corporation’s (“PBGC”) regulations imposing “reasonable conditions” on the use of COVID-19 relief funds.  The Yellow Corp. decision offers another example of…

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Restoring the Constitution’s Separation of Powers: Chevron’s Demise and the Promise of Loper Bright 

On September 17, 1787—today, 238 years ago—a momentous event took place in Philadelphia, Pennsylvania. Delegates from the thirteen States, who were assembled in convention, signed our United States Constitution. Although the Constitution was not ratified until the next year, its completion and presentation to the States for adoption marked the beginning of a radical restructuring…

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Second Circuit Upholds FCC Forfeiture After Identifying Delegation of Discretionary Authority as Required Under Loper Bright

Last week, in Verizon Communications Inc. v. Federal Communications Commission, the Second Circuit rejected a petition for review of a forfeiture order imposing nearly $47 million in penalties for violation of the confidentiality provisions of the federal Communications Act.  In doing so, the Circuit offered an important example of how courts will apply the de…

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New Article on Loper Bright, Interpretive Rules, and Sub-regulatory Guidance 

The University of New Hampshire Law Review recently published an article by University of Tulsa law professor Gwendolyn Savitz entitled “Interpretive Rules are the New Regulations: Agency Guidance After Loper Bright.”  The article explores the impact Loper Bright might have on agencies turning to interpretive rules to bypass notice-and-comment rulemaking and, potentially, searching judicial review…

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D.C. Circuit Accepts FERC Regulatory Interpretation Previously Upheld under Chevron Step-Two 

In a long-awaited remand decision, the D.C. Circuit in Solar Energy Industries Ass’n v. Federal Energy Regulatory Commission upheld FERC’s regulatory interpretation of the Public Utility Regulatory Policies Act (“PURPA”).  The Circuit previously sided with FERC last year when it concluded the agency’s position was “reasonable” under Chevron Step Two, in light of supposed statutory…

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