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".
The decision involved a legal challenge to a change in the U.S. government's interpretation of the word "source" in the Clean Air Act of 1963. The Act did not precisely define what constituted a "source" of air pollution. The Environmental Protection Agency (EPA) initially defined "source" to cover essentially any significant change or addition to a plant or factory. In 1981, the EPA changed its definition to mean only an entire plant or factory. This allowed companies to build new projects without going through the EPA's lengthy new review process if they simultaneously modified other parts of their plant to reduce emissions, avoiding any net change. Natural Resources Defense Council, an environmentalist advocacy group, challenged the legality of the EPA's new definition. NRDC won the case in a federal court, but the Supreme Court overturned that decision and ruled in favor of Chevron on the grounds that the courts should broadly defer to EPA and other independent regulatory agencies.
Chevron was one of the most important decisions in U.S. administrative law and was cited in thousands of cases. Forty years later, in June 2024, the Supreme Court overruled Chevron in Loper Bright Enterprises v. Raimondo, on the grounds that it conflicts with the Administrative Procedure Act.