What is the two-step Chevron framework for reviewing agency interpretations of statutes?

What is the two-step Chevron framework for reviewing agency interpretations of statutes?

• A. Step 1 Determine If The Statute Is Ambiguous; Step 2 If Ambiguous, Defer To The Agency’s Reasonable Interpretation.
• B. Step 1 Defer To Agency; Step 2 Determine Ambiguity.
• C. Step 1 Consider Legislative History; Step 2 Ignore Agency Interpretation.
• D. Step 1 Apply Plain Meaning; Step 2 Apply Constitutional Avoidance.

Answer: (A)

Chevron deference analyzes how courts review agency interpretations of statutes they administer. The first step asks whether the statute’s language clearly resolves the issue. If the text is unambiguous, the court applies that plain meaning and does not defer to the agency. If the statute is ambiguous or silent on the point, the court moves to the second step and defers to the agency’s reasonable interpretation, giving weight to the agency’s expertise in implementing the statute. But this deference isn’t limitless—the interpretation must be reasonable and consistent with the statute’s structure and purpose. This is why the correct framework starts by checking ambiguity and only then allows deference to the agency’s reasonable view. Choices that place deference ahead of assessing ambiguity, or that rely on legislative history, or that invoke plain meaning alongside doctrines like constitutional avoidance, don’t fit Chevron’s process.

Chevron deference analyzes how courts review agency interpretations of statutes they administer. The first step asks whether the statute’s language clearly resolves the issue. If the text is unambiguous, the court applies that plain meaning and does not defer to the agency. If the statute is ambiguous or silent on the point, the court moves to the second step and defers to the agency’s reasonable interpretation, giving weight to the agency’s expertise in implementing the statute. But this deference isn’t limitless—the interpretation must be reasonable and consistent with the statute’s structure and purpose.

This is why the correct framework starts by checking ambiguity and only then allows deference to the agency’s reasonable view. Choices that place deference ahead of assessing ambiguity, or that rely on legislative history, or that invoke plain meaning alongside doctrines like constitutional avoidance, don’t fit Chevron’s process.