Before June 28, unless you were a lawyer or federal agency employee, the term “Chevron” probably meant little more to you than a gas station. But on June 28, when the Supreme Court overturned the long-standing “Chevron Doctrine”—which previously directed lower courts to defer to a federal agency’s reasonable interpretation of a silent or ambiguous statute—regulated industry notched what was hailed a sweeping win and “Chevron” became part of our daily vernacular.
Now, after having spent the summer pouring over cases, articles, and thought leadership on the matter, we’re not sure the win is so sweeping—especially in the U.S. Food & Drug Administration (“FDA” or the “Agency”) arena.
