McLaughlin Chiropractic Associates v. McKesson Corporation

The Hobbs Act does not preclude judicial review of an agency's statutory interpretation in district court enforcement proceedings, and district courts must independently determine whether the agency's interpretation is correct under ordinary principles of statutory interpretation. Justice Brett Kavanaugh authored the 6-3 majority opinion of the Court. Courts may grant pre-enforcement review of agency orders through three types of statutes: those that expressly preclude subsequent judicial review in enforcement proceedings (like the Clean Water Act), those that expressly authorize review in both contexts, and those that remain silent on enforcement proceedings (like the Hobbs Act). The Hobbs Act falls into the third category, which triggers a default rule allowing district courts to independently assess agency interpretations. The Administrative Procedure Act codifies this presumption of judicial review, stating that “agency action is subject to judicial review in civil or criminal proceedings for judicial enforcement” unless prior review was adequate and exclusive. The phrase “determine the validity” in the Hobbs Act refers specifically to entering declaratory judgments in pre-enforcement proceedings, not to the broader process of evaluating an agency interpretation’s correctness in enforcement actions. The Emergency Price Control Act precedent from Yakus v. United States does not control because that wartime statute contained two provisions working together: exclusive jurisdiction language plus an express prohibition against other courts considering validity. Congress chose not to include this second, prohibitive provision when enacting the Hobbs Act six years later, demonstrating its intent not to preclude enforcement-stage review. Practical concerns about potential court disagreements do not override statutory text and administrative law principles, as circuit splits followed by Supreme Court review represent the ordinary judicial process. Requiring all potentially affected parties to challenge every agency order within 60 days or lose their rights would be impractical and unfair, particularly for entities that did not exist when orders issued or had no reason to anticipate future enforcement proceedings. Justice Elena Kagan authored a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson, arguing that the Hobbs Act's grant of “exclusive jurisdiction” to appellate courts to “determine the validity” of agency orders plainly precludes district courts from making such determinations in enforcement proceedings.