The question
Whether the Hobbs Act requires a district court in a civil enforcement proceeding to follow an agency's interpretation of a statute, or whether the court must independently determine the statute's meaning.
McLaughlin Chiropractic Associates, Inc. v. McKesson Corp.
What the Court decided
The Court held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency's interpretation of a statute. District courts must independently determine what the law means under ordinary principles of statutory interpretation, while giving appropriate respect to the agency's view. The reason is that the Hobbs Act is silent about judicial review in enforcement proceedings, so the default rule codified in the Administrative Procedure Act applies, and the Act's grant of exclusive jurisdiction to courts of appeals to determine the validity of agency orders refers to declaratory judgments in pre-enforcement proceedings, not to a district court's liability determination in an enforcement suit.
How the justices split
6-3The Court's opinion
Kavanaugh, joined by Roberts, Thomas, Alito, Gorsuch, Barrett
The Hobbs Act is silent about judicial review in enforcement proceedings, so the default rule applies: district courts must independently determine whether an agency's statutory interpretation is correct rather than being bound by it. This presumption of judicial review is codified in the Administrative Procedure Act, which subjects agency action to review in enforcement proceedings absent a prior, adequate, and exclusive opportunity for review. The Act's grant of exclusive jurisdiction to courts of appeals to determine the validity of agency orders refers to declaratory judgments in pre-enforcement proceedings, and a district court that disagrees with an agency's interpretation in an enforcement proceeding decides liability under the correct reading rather than issuing a declaratory judgment determining the order's validity.
Dissenting
Kagan, joined by Sotomayor, Jackson
Kagan filed a dissenting opinion, joined by Sotomayor and Jackson. The syllabus does not state the substance of the dissent's reasoning beyond that it disagreed with the majority's holding on the effect of the Hobbs Act in enforcement proceedings.
How we know · 5 sourced claims
The Court held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency's interpretation of a statute.
Source: syllabus, Held
District courts must independently determine the law's meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency's interpretation.
Source: syllabus, Held
The Administrative Procedure Act codifies a presumption that agency action is subject to judicial review in enforcement proceedings except where there is prior, adequate, and exclusive opportunity for review.
Source: syllabus, Held
Kavanaugh delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Gorsuch, and Barrett.
Source: syllabus, lineup
Kagan filed a dissenting opinion, joined by Sotomayor and Jackson.
Source: syllabus, lineup