Michigan v. Environmental Protection Agency Case Brief Summary | Law Case Explained

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Michigan v. Environmental Protection Agency | 576 U.S. 743 (2015)

If a federal statute is administered by an administrative agency, it’s arguable that the agency, which has domain expertise, is in a better position than courts to interpret statutory ambiguities. That understanding’s led to a rule of judicial deference known as the Chevron doctrine. In Michigan versus Environmental Protection Agency, we explore that doctrine and its limits.

Amendments to the federal Clean Air Act in 1990 established the National Emissions Standards for Hazardous Air Pollutants Program, which targeted certain sources of hazardous air pollutants for regulation by the Environmental Protection Agency, or EPA. With regard to fossil-fuel-based power plants, the act instructed the EPA to study the public-health risks posed by power-plant emissions, and only regulate power plants if the study showed that regulation was, quote, “appropriate and necessary,” unquote. The EPA interpreted the statutory appropriate-and-necessary directive as not requiring consideration of costs.

After conducting its study, the EPA determined that power-plant regulation was both appropriate and necessary, and power plants were therefore subject to regulation under the hazardous-air-pollutants program. An impact analysis showed that regulation was expected to cost power plants nine-point-six billion dollars per year, while yielding benefits valued at only four to six million dollars per year.

Various parties, including twenty-three states, filed suit against the EPA, challenging its conclusion that it wasn’t required to consider costs when determining if regulation was appropriate and necessary.

The DC Circuit upheld the EPA’s decision, and the United States Supreme Court granted cert.

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