Skidmore v. Swift & Co.

Definition

Skidmore v. Swift & Co. is a landmark Supreme Court case from 1944 that established the principle of judicial review of agency actions and provided a framework for evaluating the deference given to administrative agencies' interpretations of statutes. This case underscored the importance of agency expertise and set forth criteria for when courts should respect an agency's interpretation, emphasizing factors such as the agency's experience, consistency, and the thoroughness of its reasoning.

5 Must Know Facts For Your Next Test

1. The case arose when Skidmore challenged Swift & Co.'s classification of its employees, which affected wage determinations under the Fair Labor Standards Act.
2. The Supreme Court ruled that administrative interpretations of laws should be given varying degrees of deference based on the agency's expertise and the circumstances surrounding its interpretation.
3. The decision emphasized that while agencies should be respected for their expertise, their interpretations must still be reasoned and grounded in statutory language.
4. Skidmore v. Swift & Co. set the stage for future cases that would further refine the balance between judicial oversight and agency discretion in interpreting laws.
5. This case marked a shift toward recognizing the practical implications of agency regulations in the enforcement of labor standards, influencing how courts interact with administrative interpretations in subsequent decisions.

Review Questions

• How did Skidmore v. Swift & Co. influence the way courts evaluate administrative agency interpretations?
  • Skidmore v. Swift & Co. significantly influenced judicial evaluation of administrative agency interpretations by introducing a framework for determining the level of deference given to these interpretations. The Court established that deference should depend on several factors including the agency's expertise, consistency in its interpretations, and whether its reasoning was thorough. This decision highlighted that while agencies have special knowledge, their interpretations must still adhere to statutory requirements and rationality.
• Discuss the relationship between Skidmore v. Swift & Co. and the later development of Chevron deference.
  • Skidmore v. Swift & Co. laid foundational principles that would later be built upon in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. The Skidmore case established that courts should consider an agency’s expertise and thoroughness when evaluating its statutory interpretations, leading to a more structured approach in Chevron where courts are compelled to defer to reasonable agency interpretations of ambiguous statutes. Both cases emphasize judicial respect for agency knowledge but also underscore the necessity for agencies to provide clear and reasoned explanations for their decisions.
• Evaluate the broader implications of Skidmore v. Swift & Co. on the balance between judicial authority and administrative agency power in U.S. law.
  • The broader implications of Skidmore v. Swift & Co. reflect a critical balancing act between maintaining judicial authority and acknowledging administrative agency power in U.S. law. By establishing criteria for judicial review that recognized both agency expertise and accountability, this case opened the door for a more nuanced interaction between courts and agencies. It underscored that while agencies play a crucial role in implementing complex regulations, they must do so within a framework that respects statutory intent and promotes fairness, thereby influencing how future cases navigate the delicate relationship between legislative authority and regulatory enforcement.

Related terms

Chevron Deference: A legal doctrine that compels courts to defer to an agency's interpretation of a statute it administers when the statute is ambiguous and the agency's interpretation is reasonable.

Administrative Procedure Act (APA): A U.S. federal statute that governs the way federal administrative agencies may propose and establish regulations, providing a framework for judicial review of agency actions.

Arbitrary and Capricious Standard: A standard used by courts to review the actions of administrative agencies, which requires that the agency's decision be based on a reasonable consideration of the relevant factors and not be irrational or unreasonable.