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Law School Case Brief

Indep. Ins. Agents of Am. v. Ludwig - 302 U.S. App. D.C. 268, 997 F.2d 958 (1993)


In examining an agency's interpretation of a statute, a court searches for an unambiguously expressed intent of Congress that addresses the precise question at issue. If a court finds such an intent, that is the end of the matter; the court must enforce it. If a court does not, it must defer to the agency's interpretation so long as it is permissible.


Appellants, insurance trade associations, filed an action against appellee Comptroller of the Currency, a federal agency, arguing that the Comptroller had exceeded its statutory authority in its interpretation of the National Bank Act (National Bank Act), 18 U.S.C.S. § 92 (1978). The Comptroller interpreted the statute to suggest that insurance sales were not restricted by geographical regions. The district court granted the Comptroller's motion for summary judgment. In an earlier decision, the Court of Appeals for the District of Columbia  reversed on the ground that Congress had repealed § 92 in 1918; hence, there was no legal authority to support the Comptroller's ruling. The United States Supreme Court found that section 92 had not been repealed and remanded the case back again to Court of Appeals.


Was the Comptroller’s interpretation of the National Bank Act (National Bank Act), 18 U.S.C.S. (1978) a valid interpretation?




On remand from the U.S. Supreme Court, the Court of Appeals held that no unambiguous congressional intent existed in the words of the National Bank Act or its legislative history to suggest that insurance sales were restricted by geographical regions. Appellee's interpretation was a permissible construction of the statute because it was not inconsistent with any sufficiently clear statutory policy. The interpretation did not deviate from prior policy because informal, unpublished letters were not final decisions.

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