Supreme Court Overturns Chevron: Implications for ERISA Plan Administration

Introduction

The Chevron doctrine, established in the 1984 Supreme Court case Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., instructed courts to defer to agency interpretations of ambiguous statutes due to the agencies’ specialized expertise. Chevron promoted consistency and predictability in regulatory interpretation but faced criticism for allowing excessive agency power and reducing judicial oversight. These concerns led to its overturning in the 2024 Supreme Court decision in Loper Bright Enterprises v. Raimondo, which requires courts to independently interpret statutes without deferring to agency interpretations based on statutory ambiguity.

Former Policy Under Chevron

Chevron mandated that if a statute was clear and unambiguous, courts must follow Congress’s explicit intent. If ambiguous, courts should defer to the agency’s reasonable interpretation, given their expertise.

New Policy

Under the new policy, courts must directly resolve ambiguities in statutory language using traditional tools of statutory construction, ensuring the judiciary maintains its constitutional role in interpreting the law. While agencies’ expertise can inform courts, their interpretations are not binding. This approach reinforces the separation of powers, limiting administrative agencies’ authority and reaffirming the judiciary’s role in statutory interpretation, promoting greater consistency and judicial oversight in federal laws.

Conclusion

The Supreme Court’s decision in Loper Bright Enterprises v. Raimondo marks a pivotal shift in administrative law by overruling Chevron deference. Courts must now independently interpret statutes without defaulting to agency interpretations in cases of ambiguity, reaffirming the judiciary’s constitutional role. The overturning of Chevron could significantly impact the administration and interpretation of rules governing Employee Retirement Income Security Act (ERISA) plans. The Department of the Treasury (i.e., IRS), the Department of Labor, and the Department of Health and Human Services collectively oversee ERISA health and pension plans and routinely issue administrative guidance on precise issues. Going forward, it is likely that many of these administrative pronouncements will be litigated. The agencies will have to be mindful of this when issuing future guidance.