The Demise of the Chevron Deference Doctrine: The New Landscape of Administrative Law in the United States

Abstract

This article examines the collapse of the Chevron deference doctrine, a foundational principle in American administrative law that required courts to defer to reasonable agency interpretations where statutory language was ambiguous. Over the course of four decades, this doctrine functioned as a central mechanism for maintaining institutional equilibrium between the judiciary and the executive, operating under the presumption that administrative agencies possess superior subject-matter expertise and greater political accountability than courts. Nevertheless, Chevron deference has increasingly come under constitutional criticism for eroding the judiciary’s core interpretive function and for conflicting with Section 706 of the Administrative Procedure Act (APA), which mandates that courts independently determine questions of law. A structural turning point emerged in the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo (2024), which unequivocally overruled Chevron and held that the doctrine violated the separation of powers and was incompatible with the APA’s textual command. This article offers a comprehensive analysis of the doctrinal trajectory of Chevron, beginning with its historical and philosophical foundations, including its three normative pillars—presumed congressional intent, agency expertise, and political accountability—and tracing its expansion through key precedents, as well as its gradual limitation through the emergence of the Major Questions Doctrine. Particular attention is paid to Loper Bright, with a comparative evaluation of the majority and dissenting opinions, to illuminate the competing constitutional visions concerning the role of the judiciary and the binding authority of past precedent. In its final section, the article advances a set of policy-oriented recommendations for navigating the post-Chevron administrative landscape. These include: the legislative clarification and narrowing of delegated authority to administrative agencies; the structured reinstatement of Skidmore deference, grounded in transparent, reasoned, and persuasive agency decision-making; and the development of more robust judicial review standards under the APA. Together, these proposals aim to preserve the rule of law and democratic legitimacy in a rebalanced administrative state where the judiciary resumes its central role as the final interpreter of statutory meaning.