In a landmark decision that has sent ripples through the agricultural sector, the Supreme Court’s ruling in Loper Bright Enterprises v. Raimondo has overturned the longstanding “Chevron doctrine,” a move that promises to reshape the landscape of agricultural, food, and environmental law. The decision, handed down in June 2024, has significant implications for how these industries are regulated, shifting the balance of power between federal agencies and the courts.
For nearly four decades, the Chevron doctrine had guided courts in deferring to federal agencies’ reasonable interpretations of ambiguous statutory language. This principle, established in the 1984 case Chevron U.S.A., Inc. v. Natural Resource Defense Council, Inc., had become a cornerstone of administrative law, allowing agencies to interpret and implement laws with a degree of autonomy. However, the Supreme Court’s recent decision has upended this dynamic, instructing courts that they may not simply defer to agency interpretations of the law due to ambiguity.
John Dillard, principal attorney at Washington, D.C.-based OFW Law, highlighted the seismic shift this decision represents. “For decades, under Chevron, courts largely relied on agencies to interpret statutes,” Dillard said. “Now, courts will scrutinize agency interpretations more closely, which could significantly alter how agricultural laws and regulations are implemented.” Dillard, who leads OFW Law’s U.S. Department of Agriculture practice, represents clients across the food and agriculture sectors in regulatory, enforcement, and litigation matters.
The implications of this decision are vast and far-reaching. From how the USDA administers farm programs to how the FDA interprets food safety rules, the ruling in Loper Bright Enterprises v. Raimondo will have a profound impact on the agricultural industry. “The impact of the decision on Chevron can’t be understated,” Dillard emphasized. “It’s a big decision out of D.C. that yields changes for the country’s agriculture.”
Arkansas-based attorney Grant Ballard echoed Dillard’s sentiments, noting that the agricultural industry will need to navigate this new legal terrain carefully. “This is new territory that the agricultural industry will have to navigate,” Ballard said. “Agencies now have far less authority to interpret their own regulations, and courts will play a much greater role.” Ballard, a partner at Ark Ag Law, PLLC, represents farmers and ranchers in a variety of legal matters, including disputes against federal agencies.
The annual Mid-South conference will provide a platform for both Dillard and Ballard to explore these implications in depth. Their session will delve into the practical effects of the Supreme Court’s decision, offering insights and guidance for agricultural stakeholders as they adapt to this new legal landscape. As the industry grapples with these changes, the expertise of legal professionals like Dillard and Ballard will be invaluable in helping farmers, ranchers, and other stakeholders navigate the complexities of the post-Chevron era.