National Electrical Manufacturers Ass'n v. United States Department of Energy
654 F.3d 496
| 4th Cir. | 2011Background
- NEMA petitions for review of the DOE final rule setting energy standards for small electric motors (.25–3 hp).
- Final Rule defines “small electric motor” as a NEMA general purpose AC single‑speed induction motor built in a two‑digit frame series per MG1‑1987.
- NEMA argues the statutory definition unambiguously excludes motors above 1 hp and certain under‑1 hp motors from coverage.
- DOE contends the statutory definition is ambiguous and MG1‑1987 informs the meaning but does not unambiguously impose horsepower limits across both clauses.
- Court applies Chevron to interpret the two‑clause definition and defers to a reasonable DOE interpretation.
- Dissent criticizes the majority’s Chevron approach and view of MG1‑1987’s incorporation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the statute unambiguously incorporate horsepower limits? | NEMA argues MG1‑1987 imposes horsepower limits in the definition. | DOE argues the second clause ties to frame size; not unambiguously incorporating horsepower limits. | No; unambiguous incorporation is not shown. |
| What does “in accordance with MG1‑1987” in the second clause mean? | NEMA contends it unambiguously includes MG1‑1987 Parts 10–12 horsepower limits. | DOE interprets it to require appropriate frame size only, not all Parts 10–12 limits. | Second clause requires frame size but does not unambiguously import horsepower divisions. |
| Is DOE entitled to Chevron deference for its interpretation? | NEMA contends DOE’s post hoc litigation position shows no deference should attach. | DOE’s interpretation is a reasonable policy choice based on market realities. | Yes; DOE’s interpretation is reasonable and entitled to Chevron deference. |
Key Cases Cited
- Chevron U.S.A. Inc. v. NRDC, 467 U.S. 837 (1984) (establishes Chevron deference framework)
- Barnhart v. Thomas, 540 U.S. 20 (2003) (last antecedent/step-one and step-two analysis guidance)
- National R.R. Passenger Corp. v. Boston & Maine Corp., 503 U.S. 407 (1992) (statutory interpretation context and deference)
- Ami Online, Inc. v. AT&T Corp., 243 F.3d 812 (4th Cir. 2001) (Chevron step-one/step-two application and technical expertise)
- General Dynamics Land Systems, Inc. v. Cline, 540 U.S. 581 (2004) (legislative history vs. text in Chevron context)
- Elm Grove Coal Co. v. Dir., O.W.C.P., 480 F.3d 278 (4th Cir. 2007) (use of statutory text and canons in Chevron analysis)