New June 20 decisions reshape sentencing, agency deference, and standing law—here’s what lawyers must know.
On June 20, 2025, the U.S. Supreme Court released three significant rulings that touch on major legal doctrines—criminal sentencing, agency deference in civil enforcement, and Article III standing. These rulings not only clarify narrow statutory questions but also reflect broader ideological divides on the bench. Below is a breakdown of Esteras v. United States, McLaughlin Chiropractic Associates v. McKesson Corp., and Diamond Alternative Energy v. EPA, crafted for practicing attorneys, law students, and legal scholars navigating federal law’s evolving terrain.
⚖️ 1. Esteras v. United States: Sentencing vs. Supervised Release—Retribution Left Out
In a 7–2 opinion authored by Justice Amy Coney Barrett, the Court ruled that when deciding whether to revoke supervised release, courts may only consider the sentencing factors listed in the supervised release statute (18 U.S.C. § 3583)—excluding broader sentencing purposes like retribution.
🔍 Core Holding: Judges revoking supervised release may not consider retribution, a key goal in original sentencing, because Congress chose to omit that factor in the specific statutory framework for supervised release.
Barrett emphasized that Congress’s selective incorporation of sentencing factors reveals legislative intent. “Congress’s decision to enumerate most of the sentencing factors while omitting [retribution] raises a strong inference that courts may not consider that factor,” she wrote.
🗣️ Concurring Opinions:
- Sotomayor strongly affirmed that retribution has no place at all in supervised release revocation decisions.
- Justice Jackson criticized the opinion for being unnecessarily complex, suggesting that the issue could have been resolved more simply.
🟥 Dissent: Justice Alito, joined by Justice Gorsuch, pushed back, asserting that the statutory text and structure do not support the majority’s restrictive interpretation.
💡 Takeaway: This ruling narrows judicial discretion and reinforces the distinct purpose of supervised release—reintegration and public safety, not punishment.
📠 2. McLaughlin Chiropractic Associates v. McKesson Corp.: District Courts Can Disagree with Agency Interpretations
In a 6–3 decision authored by Justice Brett Kavanaugh, the Court ruled that district courts are not bound by agency interpretations—in this case, the FCC’s reading of the Telephone Consumer Protection Act (TCPA)—when deciding civil enforcement proceedings.
At issue was whether the FCC’s interpretation that TCPA fax advertising restrictions don’t apply to online fax services must be accepted by courts. The Supreme Court said: No.
🧾 Kavanaugh’s Opinion:
District courts may independently evaluate a statute’s meaning, giving “appropriate respect” to the agency’s view but not deferring outright, especially in enforcement contexts. The Hobbs Act, which governs judicial review of agency orders, does not preclude such evaluation.
⚖️ Dissent: Justice Elena Kagan, joined by Sotomayor and Jackson, criticized this ruling as undermining statutory review mechanisms. Kagan argued that the Hobbs Act bars collateral challenges when pre-enforcement review was not pursued.
💡 Takeaway: This ruling strengthens judicial independence in statutory interpretation during agency enforcement actions. It’s a potential blow to agency authority and may preview future challenges to Chevron deference.
🌱 3. Diamond Alternative Energy v. EPA: Fuel Producers Have Standing to Sue Over EPA’s Approval of California’s EV Rules
In another 7–2 ruling by Justice Kavanaugh, the Court held that fuel producers have Article III standing to challenge the EPA’s approval of California’s low-emission vehicle regulations under the Clean Air Act.
📜 Key Question: Can fuel producers sue the EPA over California’s stricter environmental rules—despite the rules originating at the state level?
✅ Answer: Yes. The Court ruled that producers have standing because invalidating these regulations would likely redress monetary harms, like increased compliance costs or reduced market share.
🟥 Dissents:
- Sotomayor wanted the D.C. Circuit to reanalyze the redressability issue.
- Jackson challenged the standing theory as inconsistent with how the Court treats less powerful litigants, suggesting preferential treatment for corporate plaintiffs.
💡 Takeaway: This decision lowers the bar for economic injuries as a basis for standing, giving industry challengers a broader avenue to dispute environmental and administrative actions.
🧠 Legal Implications & Practice Notes
For Criminal Defense and Sentencing Attorneys:
The Esteras ruling changes the sentencing calculus—retribution is no longer a valid justification for revoking supervised release. Defense strategies should emphasize rehabilitation and compliance, not prior misconduct.
For Administrative and Civil Litigators:
McLaughlin is part of a growing trend away from agency deference, hinting at the Court’s willingness to revisit Chevron in the near future. Watch this space.
For Environmental and Energy Counsel:
Diamond Alternative Energy expands standing for economic stakeholders, potentially inviting more legal challenges to state and federal climate regulations. A regulatory landscape once insulated is now legally vulnerable.
#SupremeCourt #LegalNews #SCOTUS #CriminalLaw #EnvironmentalLaw #AdministrativeLaw #StandingDoctrine #ChevronDeference #LawStudents #LegalUpdate #LawPractice #TCPA #SupervisedRelease
Source: https://www.scotusblog.com/2025/06/additional-opinions-from-friday-june-20/
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