Docket 23-1226
McLaughlin Chiropractic Associates, Inc. v. McKesson Corp.
DecidedJun 20, 2025
6-3decision
Source: CourtListener.
Courts can independently review FCC fax rules in private lawsuits, not just in pre-enforcement challenges
Impact7/10
What it does
The Court held that the Hobbs Act does not bind district courts to an agency's interpretation of a statute when that statute is at issue in a civil enforcement proceeding. District courts must independently determine what the law means using ordinary tools of legal interpretation, while giving appropriate — but not absolute — weight to the agency's view. This overturns the approach used by the Ninth Circuit and several other courts of appeals, which had treated agency orders covered by the Hobbs Act as binding on district courts in later lawsuits.
Who benefits
Private parties — such as businesses or individuals — who are sued or who sue under a federal statute that an agency has interpreted, and who want to argue in district court that the agency's interpretation of that statute is wrong. Defendants in civil enforcement suits who were previously barred from challenging agency legal interpretations in district court also benefit.
Who is affected
Federal agencies whose legal interpretations of statutes — such as the FCC's reading of the Telephone Consumer Protection Act — can now be challenged and rejected by district courts in private civil lawsuits, not just in dedicated pre-enforcement proceedings in courts of appeals. Parties who structured their conduct in reliance on an agency's interpretation may find that interpretation overturned in later litigation.
Practical impact
Businesses and individuals sued under federal statutes that agencies have interpreted — including the Telephone Consumer Protection Act's rules on fax advertisements — may now argue in district court that the agency's interpretation is wrong, even if no one challenged that interpretation in a pre-enforcement proceeding within the Hobbs Act's 60-day window. On remand, the district court in this case must independently decide whether the FCC was correct that online fax services fall outside the TCPA's coverage, potentially reopening a large class action that had been dismissed based on the FCC's order. More broadly, agency interpretations of statutes covered by the Hobbs Act — spanning the FCC, Department of Transportation, Nuclear Regulatory Commission, and others — are now subject to challenge in district court civil proceedings, not just in dedicated appellate review.
Majority — Kavanaugh
Joined by: Roberts, Thomas, Alito, Gorsuch, Barrett
The majority held that the default rule in administrative law — backed by the text of the Administrative Procedure Act (a law governing how courts review agency decisions) — is that parties in civil enforcement proceedings may challenge an agency's interpretation of a statute, and district courts may independently decide whether that interpretation is correct. The Court reasoned that the Hobbs Act's grant of "exclusive jurisdiction" to courts of appeals to "determine the validity" of agency orders refers specifically to entering a declaratory judgment (a formal court ruling declaring something valid or invalid) in a pre-enforcement proceeding, not to the general process of interpreting a statute in a later lawsuit. Because the Hobbs Act — unlike the Clean Water Act, CERCLA, and the Clean Air Act — does not contain language expressly barring district courts from reviewing agency interpretations in enforcement proceedings, the default rule applies and district court review is available. The majority also distinguished the key precedent relied on by the other side, Yakus v. United States, noting that the wartime law in that case contained a second, explicit sentence barring all other courts from even "considering" the validity of covered regulations — language that Congress deliberately chose not to include when it enacted the Hobbs Act six years later. Finally, the majority rejected the practical concern that allowing district courts to disagree with agencies would create chaos, noting that circuit splits are a normal part of the legal system and that requiring all potentially affected parties to file pre-enforcement challenges within 60 days or forever lose their right to contest an agency's interpretation would be impractical and unfair.
Dissent reasoning
The dissent argued that the Hobbs Act's plain text already answers the question: by giving courts of appeals "exclusive jurisdiction" to "determine the validity" of covered agency orders, the Act necessarily strips district courts of any power to make that same determination in a later lawsuit. Justice Kagan wrote that when a party in a district court asks that court to disregard an agency order because it misreads a statute, the party is asking the court to "determine" whether the order is "valid" — exactly what the Hobbs Act reserves for courts of appeals alone. The dissent contended that the majority's reading improperly narrows the phrase "determine the validity" by silently inserting the words "issue a declaratory judgment" — a form of adding words Congress did not write. The dissent also argued that prior Supreme Court decisions, including Yakus and Port of Boston Marine Terminal Assn. v. Rederiaktiebolaget Transatlantic, already held that Hobbs Act-type statutes prevent exactly this kind of later, collateral challenge to agency action in district court, and that the majority's attempt to limit those cases to narrow estoppel principles misreads their holdings. Finally, the dissent warned that the majority's ruling undermines the Hobbs Act's core purpose — providing quick, final resolution of challenges to agency rules — by allowing any party, at any point in the future, to relitigate the validity of even well-settled agency orders, and by letting regulated parties ignore agency rules and wait to contest them only if an enforcement action is ever brought.
Constitutional question
Does the Hobbs Act — a federal law that gives courts of appeals the exclusive power to review certain agency orders before they are enforced — prevent district courts in later civil lawsuits from independently deciding whether an agency correctly interpreted a statute?
Precedent changed
Port of Boston Marine Terminal Assn. v. Rederiaktiebolaget Transatlantic, 400 U.S. 62 (1970), is narrowed: the majority confined it to situations involving estoppel or preclusion between parties who were already opposed in an agency proceeding, rejecting the broader reading that the Hobbs Act categorically bars district courts from reviewing agency interpretations in enforcement proceedings.