The U.S. Supreme Court in Loper Bright Enterprises v. Raimondo has unsettled modern foundations of administrative law by overturning its own decision of 40 years ago in Chevron U.S.A. v. Natural Resources Defense Council, 467 U.S. 837 (1984). Chevron deference, as the doctrine became known, required considerable and often abject deference to an agency's interpretation of a statute that Congress has tasked it with enforcing. Chevron deference is a two-step process that first asks whether the statutory provision in question is clear and unambiguous and, if not, then asks whether the agency's interpretation of the unclear statute is reasonable. In practice, the second step of Chevron is all but toothless; once the text of a statute has been deemed ambiguous, one can hardly find a case in which the court then determines that the agency interpretation of that ambiguous statute was "unreasonable," even if it is against the weight of analysis using the multitude of interpretive tools that courts otherwise employ to construe statutory text.