594 U.S. 382
SCOTUS2021Background
- The Renewable Fuel Program (RFP) requires most refineries to blend renewable fuels; Congress created a blanket small‑refinery exemption through 2010 and authorized further relief.
- §7545(o)(9)(A)(ii) directed EPA to "extend the exemption" for ≥2 years if the Secretary of Energy found "disproportionate economic hardship."
- §7545(o)(9)(B)(i) permits "A small refinery [to] at any time petition the Administrator for an extension of the exemption under subparagraph (A) for the reason of disproportionate economic hardship."
- Three small refineries had prior exemptions that lapsed, later petitioned under (B)(i), and EPA granted new exemptions; renewable‑fuel producers challenged those grants.
- The Tenth Circuit vacated EPA’s orders, holding that an "extension" requires unbroken continuity and past lapse permanently bars later extensions; the Supreme Court granted certiorari and reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of "extension" in §7545(o)(9)(B)(i) — temporal vs. non‑temporal | "Extension" denotes prolonging a period and thus requires continuity | Could mean the agency’s act of granting an exemption (non‑temporal) | Court: "extension" is used temporally (lengthening a period) based on neighboring text and titles |
| Whether a prior lapse permanently bars later extensions | Lapse makes a refinery ineligible for any later "extension" (continuity requirement) | A lapse does not preclude petitioning later; an extension may resume after interruption | Court: No continuity requirement; a refinery whose exemption lapsed may obtain an extension under (B)(i) |
| Whether Chevron deference resolves meaning (EPA regulation interpreting "extension") | EPA had previously defended a regulatory interpretation before the Tenth Circuit | Petitioners invoked the regulation but the government did not press Chevron on certiorari | Court: Declined to decide Chevron deference because the federal government did not invoke it here |
Key Cases Cited
- Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (establishes administrative deference framework)
- FDIC v. Meyer, 510 U.S. 471 (general rule: undefined statutory terms get ordinary meaning)
- United States v. Gonzales, 520 U.S. 1 ("at any time" supports expansive meaning)
- Taniguchi v. Kan Pacific Saipan, Ltd., 566 U.S. 560 (interpretation favors the term’s most natural reading)
- Renewable Fuels Assn. v. EPA, 948 F.3d 1206 (10th Cir. 2020) (court below vacated EPA grants, imposing continuity rule)
- Sinclair Wyoming Refining Co. v. EPA, 887 F.3d 986 (10th Cir. 2017) (discusses small‑refinery burdens)
- American Fuel & Petrochemical Mfrs. v. EPA, 937 F.3d 559 (D.C. Cir. 2019) (administration of small refinery exemption program)