On June 20, the U.S. Supreme Court reversed and remanded a lower court decision, holding that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. In this case, SCOTUS ruled that district courts must independently determine the law’s meaning under statutory interpretation, while granting appropriate respect to the agency’s interpretation. The Court clarified that the Hobbs Act’s provision of “exclusive jurisdiction” to appellate courts applies to pre-enforcement challenges seeking declaratory judgments or injunctive relief against agency orders, not to enforcement proceedings.
The case involved a healthcare company that allegedly sent unsolicited fax advertisements, prompting a suit from a medical practice under the TCPA. The plaintiff alleged that the healthcare company violated the TCPA by sending unsolicited advertisements without the required opt-out notices and sought to represent a class of recipients, including those who received faxes through online fax services. The district court, following Ninth Circuit precedent and treating an FCC order as binding, granted summary judgment to the defendant, and this decision was affirmed by the Ninth Circuit.
The Supreme Court explained that statutes like the Hobbs Act are silent regarding judicial review in enforcement proceedings, such that, under administrative law principles, district courts must determine whether an agency’s statutory interpretation is correct in enforcement proceedings. SCOTUS found no basis for reading the Hobbs Act to require district courts to afford absolute deference to the agency’s interpretation, emphasizing that the availability of pre-enforcement review does not ordinarily preclude judicial review in enforcement proceedings.
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