The U.S. Supreme Court ruled that lower courts can independently interpret statutes without adhering to the FCC's interpretations. This decision in McLaughlin Chiropractic Associates v. McKesson Corp. reverses a Ninth Circuit ruling linked to a class-action suit over unsolicited fax advertisements. It is emblematic of a judicial trend limiting federal agency authority, following similar precedents like the Loper Bright Enterprises case. The majority opinion, delivered by Justice Kavanaugh, emphasized the traditional judicial role in statutory interpretation, while dissenting justices criticized the decision's adherence to the Hobbs Act's framework.
"The District Court is not bound by the FCC's interpretation of the TCPA," Justice Brett Kavanaugh wrote for the 6-3 majority. "The District Court should interpret the statute as courts traditionally do under ordinary principles of statutory interpretation, affording appropriate respect to the agency's interpretation."
"The text of the Hobbs Act makes clear that litigants who have declined to seek pre-enforcement judicial review may not contest the statutory validity of agency action in later district-court enforcement proceedings," Supreme Court Justice Elena Kagan said in a dissenting opinion on the FCC case.
"Today's majority evades the Hobbs Act's most natural meaning by relying on a novel 'default rule' ... That rule has no foundation in our law; it emerges fully formed today from the majority's head."
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