Mclaughlin Chiropractic Associates, Inc. v. Mckesson Corp. et al.
No. 23-1226 · Decided June 20, 2025 · Reversed and remanded
Does the Hobbs Act require district courts in civil enforcement proceedings to follow an agency's interpretation of a statute? The Hobbs Act does not preclude district courts in civil enforcement proceedings from independently determining whether an agency's interpretation of a statute is correct.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT · Argued January 21, 2025
Parties — Petitioner: McLAUGHLIN CHIROPRACTIC ASSOCIATES, INC. · Respondent: McKESSON CORP. et al.
Vote & lineup6–3 on the judgment. Kavanaugh delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Gorsuch, Barrett (6). Dissent(s): Kagan (joined by Sotomayor, Jackson).
Who prevailed — Petitioner (McLaughlin Chiropractic Associates, Inc.) prevailed on the issue of whether the district court was bound by the FCC's interpretation of the TCPA.
The question

Does the Hobbs Act require district courts in civil enforcement proceedings to follow an agency's interpretation of a statute? Specifically, does the grant of "exclusive jurisdiction" to courts of appeals to "determine the validity" of FCC orders preclude district courts from independently interpreting the Telephone Consumer Protection Act (TCPA)? The Court must decide if the Hobbs Act overrides the general presumption that district courts may review agency statutory interpretations in enforcement actions.

Petitioner's argument
  • District courts should not be bound by an agency's interpretation of a statute in enforcement proceedings.
  • The Hobbs Act does not expressly preclude judicial review in such proceedings, unlike other statutes such as the Clean Water Act or CERCLA.
  • Requiring all potentially affected parties to bring pre-enforcement challenges within 60 days is impractical and unfair, particularly for parties who did not exist at the time of the order's issuance.
Respondent's argument
  • The Hobbs Act grants "exclusive jurisdiction" to courts of appeals to "determine the validity" of agency orders under 28 U.S.C. § 2342.
  • If a district court disagrees with an agency's statutory interpretation in an enforcement proceeding, it is effectively "determining the validity" of that order, which violates the Act's exclusivity provision.
  • Precedent such as *Yakus v. United States* supports the view that pre-enforcement review mechanisms preclude subsequent judicial review in enforcement proceedings.
The decision
  • The Hobbs Act does not bind district courts in civil enforcement proceedings to an agency's interpretation of a statute.
  • The Court identifies three categories of pre-enforcement review statutes: those that expressly preclude enforcement review (e.g., Clean Water Act, CERCLA, and the Clean Air Act), those that expressly authorize both, and those silent on enforcement review, such as the Hobbs Act.
  • For statutes silent on enforcement review, the default rule is that district courts must independently determine if an agency's interpretation is correct using ordinary principles of statutory interpretation, as established in *Loper Bright Enterprises v. Raimondo*.
  • This default rule is supported by a "basic presumption of judicial review" (*Weyerhaeuser Co. v. United States Fish and Wildlife Serv.*) and is codified in the Administrative Procedure Act (APA) at 5 U.S.C. § 703, which allows review unless a "prior, adequate, and exclusive opportunity for judicial review is provided by law."
  • The Court holds that the phrase "determine the validity" in 28 U.S.C. § 2342 refers to entering declaratory judgments in pre-enforcement proceedings, not the decisional process used to determine liability in enforcement actions.
  • Applying the *noscitur a sociis* canon, the Court reasons that "determine the validity" should be read as a form of relief consistent with the accompanying terms "enjoin," "set aside," and "suspend."
  • The Court distinguishes *Yakus v. United States*, noting that the Emergency Price Control Act contained an express prohibition on other courts considering validity—a provision absent from the Hobbs Act.
  • The Court further distinguishes *Port of Boston Marine Terminal Assn. v. Rederiaktiebolaget Transatlantic* and *FCC v. ITT World Communications, Inc.*, finding those cases applied to estoppel and preclusion for parties who had already litigated before an agency.
Separate opinions
Kagan, dissenting (joined by Sotomayor, Jackson)
  • Argues that "exclusive jurisdiction" means exactly what it says: only courts of appeals may determine the validity of covered agency actions, meaning district courts have no power to make that determination anew.
  • Relies on *Venner v. Michigan Central R. Co.*, *Yakus v. United States*, and *Port of Boston* to argue that the Hobbs Act prevents collateral attacks on agency orders in district courts.
  • Contends the majority's "default rule" is novel and improperly narrows the statute by reading "determine the validity" as meaning only "issue a declaratory judgment."