Supreme Court🏛️ PolicyMixed outcomeDecided: June 28, 2024

Loper Bright v. Raimondo: the end of Chevron deference and what it means for USCIS

The Supreme Court 6-3 overruled Chevron deference, in place since 1984. Courts are no longer required to defer to an agency's interpretation of an ambiguous statute. For immigration, this reshapes the weight of USCIS memos and DHS regulations.

Citation: 603 U.S. ___ (2024)|Chevronagency deferenceregulations

What happened

A group of Atlantic fishermen challenged a National Marine Fisheries Service rule requiring them to pay for onboard observers. The dispute itself was not immigration-related, but it raised a foundational question: how much must courts defer to agencies.

The case was consolidated with Relentless v. Department of Commerce, which raised the same issue from a different angle.

At stake was the doctrine from Chevron U.S.A. v. NRDC (1984) — for four decades the cornerstone of administrative law.

The court's ruling

Chief Justice Roberts wrote for the majority: Chevron is overruled. Courts must interpret ambiguous statutes themselves, using the ordinary tools of statutory construction.

Majority: Roberts, Thomas, Alito, Gorsuch, Kavanaugh, Barrett. Dissent: Kagan, Sotomayor, Jackson.

But the Court preserved Skidmore deference (1944) — an agency's view may still be "persuasive" depending on its consistency, thoroughness, and reasoning.

Why it matters

Immigration law is built around agency interpretations: the USCIS Policy Manual, BIA memos, DHS regulations. Many of them survived court review only because of Chevron.

This cuts both ways: restrictive readings (e.g., public charge, asylum bars) also lose automatic support. But favorable positions (DACA, fee waivers) become more vulnerable too.

In practice we will see wider splits across the circuits: one Circuit Court may agree with USCIS, another may not. Fewer agency wins, more litigation.

What it means for you

1

If your denial relies on a USCIS interpretation that is "derived from" the statute rather than spelled out, you may have stronger appellate odds than before 2024.

2

Don't expect USCIS to rewrite its memos on its own. Change will come through litigation, slowly.

3

Don't try this argument on your own — "agency interpretation no longer deserves Chevron deference" needs to be framed precisely in the appeal.

⚖️ Related judges

Attorney commentary

ИФ
Илья Фишкин
Immigration attorney

“Loper Bright is an earthquake, but not every client will feel it right away. A straightforward family-based green card case is unaffected. An EB-2 NIW denial under the 2022 "new" standard is now clearly worth appealing or pushing to federal court.”

“I see two layers. First, reopening already-denied cases that turned on agency "creative" interpretations. Second, new filings where you can challenge a USCIS position right in the cover letter, without invoking Chevron.”

“What to watch: a wave of high-profile circuit decisions over the next two years. Keep an eye on the 9th, 5th, and DC Circuits — that's where the big immigration storylines usually play out.”

Sources

⚠️ This material is educational and is not legal advice. Whether it applies to your case should be discussed with an attorney.

Need a breakdown of your specific situation?

Attorney consultation →