Under Chevron Step One, what must a court determine about the governing statute?

Under Chevron Step One, what must a court determine about the governing statute?

• A. The agency's interpretation controls regardless of clarity.
• B. The statute is clear and unambiguous; the agency must apply the statute as written.
• C. The court should substitute its own view of the statute.
• D. The agency may choose any interpretation that aligns with policy.

Answer: (B)

In Chevron analysis, the court first asks whether the statute being interpreted speaks clearly on the issue. If the statute is clear and unambiguous, the court must enforce the statute according to its plain terms, and the agency’s interpretation has no control. This is why the best answer is that the statute is clear and unambiguous; the agency must apply the statute as written. If the statute were ambiguous, the analysis would move to the second step, where the court would consider whether the agency’s interpretation is a permissible construction of the statute. That context helps explain why the other options don’t fit: interpreting the statute as anything other than clear and applying it as written is not allowed at Step One, and choosing an interpretation based solely on policy would not reflect the statutory text or the Chevron framework.

In Chevron analysis, the court first asks whether the statute being interpreted speaks clearly on the issue. If the statute is clear and unambiguous, the court must enforce the statute according to its plain terms, and the agency’s interpretation has no control. This is why the best answer is that the statute is clear and unambiguous; the agency must apply the statute as written.

If the statute were ambiguous, the analysis would move to the second step, where the court would consider whether the agency’s interpretation is a permissible construction of the statute. That context helps explain why the other options don’t fit: interpreting the statute as anything other than clear and applying it as written is not allowed at Step One, and choosing an interpretation based solely on policy would not reflect the statutory text or the Chevron framework.