The Supreme Court has issued an opinion in the matter of Loper Bright Enterprises, et al. v. Raimondo, Secretary of Commerce, et al. that could have broad implications for the interpretation of employee benefit laws. This decision overturns what is referred to as the Chevron Doctrine. The Chevron Doctrine was developed from a case (Chevron USA Inc. v. Natural Resources Defense Council, Inc.) rendered 40 years ago.
The Chevron Doctrine provides that administrative agencies, such as the Department of Labor, the Environmental Protection Agency, the Food and Drug Administration, Health and Human Services and so many more, have the authority to use their expertise to interpret ambiguous statutes. The decision issued June 28, 2024, reverses the Chevron Doctrine stating that it is courts and not administrative agencies who must interpret ambiguous statutes. This profound change in the way law is interpreted may have significant impact on how employee benefit law is interpreted.
We have seen a plethora of court challenges in recent years, and it is certainly plausible to expect that we will see even more as agency expertise is given less credence and courts are given more.
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