What’s the story?
The U.S. Supreme Court ended its October 2024 term on June 27, 2025, with a series of rulings on the administrative state. The Court issued 13 decisions that affected federal agency operations and oversight. The most notable opinions from the term included decisions:
- narrowing the use of nationwide injunctions,
- limiting where companies can file lawsuits to challenge regulations, and
- making it easier for third parties to challenge agency actions.
SCOTUS also clarified constitutional boundaries on agency appointments, declined to revive broad nondelegation challenges, and raised the bar for regulatory authority under ambiguous statutes.
Why does it matter?
While some decisions upheld existing agency structures or interpretations, the overall trend pointed to tighter judicial oversight. Even rulings that preserved agency discretion, such as those involving firearm rules and telecom funding, signaled that federal regulatory power will face closer scrutiny moving forward.
Here’s a snapshot of the term’s key administrative state decisions, organized by theme:
Judicial oversight and access
- In Trump v. CASA, Inc. (6–3), SCOTUS ruled lower courts exceeded their authority by issuing nationwide injunctions against an executive order limiting birthright citizenship. The decision restricts universal injunctions and requires federal courts to limit relief to the plaintiffs before them.
- In Williams v. Reed (5–4), the Court held plaintiffs do not have to exhaust state administrative remedies before filing a civil rights claim if the delays themselves are part of the legal challenge. The decision limits procedural barriers to judicial review and increases access to courts in cases involving alleged rights violations by state agencies.
- In Oklahoma v. Environmental Protection Agency (EPA) (8–0), the justices unanimously decided challenges to state-specific EPA actions under the Clean Air Act must occur in regional circuit courts, not the D.C. Circuit. The ruling decentralizes judicial review and strengthens venue limits based on geography.
- In Environmental Protection Agency v. Calumet Shreveport Refining, LLC (7–2), the Court held challenges to the EPA decision with national scope must be filed in the D.C. Circuit. The ruling limits companies from choosing favorable courts and centralizes judicial review of national EPA actions.
- In Bouarfa v. Mayorkas (9–0), the Court unanimously held courts lack jurisdiction to review the Secretary of Homeland Security’s discretionary decision to revoke a visa petition based on a sham-marriage finding. The ruling affirms limits on judicial review of discretionary agency actions under federal immigration law.
- In Nuclear Regulatory Commission (NRC) v. Texas (6–3), SCOTUS held that states and private parties not involved in the original agency proceeding lacked standing under the Hobbs Act to challenge a nuclear waste license. The Hobbs Act allows only direct parties to certain agency decisions to seek appellate review. The ruling narrows access to judicial review and leaves questions about federal licensing authority.
- In McLaughlin Chiropractic Associates v. McKesson Corp. (6–3), the Court held the Hobbs Act does not require district courts to adopt an agency’s legal interpretation when resolving private disputes. The ruling limits the binding effect of agency interpretations outside formal administrative challenges and reinforces the judiciary’s independent role in statutory interpretation.
Statutory limits and agency power
- In Diamond Alternative Energy LLC v. Environmental Protection Agency (7–2), the Court held that fuel producers had standing to challenge the EPA’s waiver allowing California to set its own vehicle emissions standards, based on the regulation’s predicted economic effects. The decision expands access to judicial review for indirectly affected parties in administrative law cases and reflects continued scrutiny of agency authority.
- In Bondi v. VanDerStok (7–2), SCOTUS decided the Bureau of Alcohol, Tobacco, Firearms (ATF) has authority under the Gun Control Act of 1968 to regulate firearm parts kits that can readily be assembled into functional weapons. The ruling affirmed the agency’s interpretation of its statutory authority, signaling judicial deference that contrasted with other decisions.
- In Seven County Infrastructure Coalition v. Eagle County, Colorado (8-0), SCOTUS unanimously held the Surface Transportation Board was not required under National Environmental Policy Act (NEPA) to assess environmental impacts of projects beyond its regulatory authority. The ruling limited the scope of environmental review obligations and affirmed judicial deference to agency decisions under NEPA.
- In City and County of San Francisco v. EPA (5–4), the justices decided the EPA exceeded its authority under the Clean Water Act by imposing permitting requirements not explicitly authorized by statute. The ruling limits agency discretion in environmental enforcement and constrains regulatory authority.
- In FCC v. Consumers’ Research (6–3), the Court upheld Congress’s delegation of authority to the Federal Communications Commission (FCC) to administer the Universal Service Fund and found no nondelegation violation in the FCC’s use of a private administrator’s projections. The ruling reaffirms the constitutionality of administrative funding structures and does not apply the nondelegation doctrine as a constraint on agency authority.
Agency structure and appointments
- In Kennedy v. Braidwood Management, Inc. (6–3), the Supreme Court held members of the U.S. Preventive Services Task Force are inferior officers who may be appointed by the Secretary of Health and Human Services. The ruling upholds the task force’s structure under the Affordable Care Act and supports executive supervision as a constitutional check on agency personnel.
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