Gonzales v. Oregon
Following is the case brief for Gonzales v. Oregon, 546 U.S. 243 (2006).
Case Summary of Gonzales v. Oregon:
- Oregon passed a physician-assisted suicide law in 1994. In 2001, the U.S. Attorney General issue a Rule stating that the law violated the Controlled Substances Act of 1970.
- Oregon sued in federal court, challenging the Attorney General’s Rule.
- The District Court and Ninth Circuit Court of Appeals held for Oregon.
- The Supreme Court affirmed those decisions. The Court found that the Attorney General’s Rule was invalid. The Controlled Substances Act does not give the Attorney General power to regulate the medical profession in general.
Gonzales v. Oregon Case Brief
Statement of the Facts:
In 1994, Oregon passed the first physician-assisted suicide law in the nation, the Oregon Death With Dignity Act. The law permitted physicians to prescribe controlled substances in lethal doses to terminally ill patients. In 2001, the U.S. Attorney General (John Ashcroft) issued an Interpretive Rule, stating that the assisted suicide law violated the Controlled Substances Act of 1970 (CSA).
The State of Oregon and several other parties challenged the Interpretive Rule in Federal District Court. The District Court issued a permanent injunction against the Rule’s enforcement. On appeal, the Ninth Circuit Court of Appeals held that the Rule was invalid as inconsistent with the constitutional balance between the States and the Federal Government. The Supreme Court granted certiorari.
Issue and Holding:
Does the CSA give the U.S. Attorney General the authority to stop physicians from prescribing drugs pursuant to a State’s assisted-suicide law? No.
The judgment of the Ninth Circuit Court of Appeals is affirmed.
Rule of Law or Legal Principle Applied:
The CSA does not give the Attorney General authority to prohibit physicians from prescribing regulated drugs consistent with a State’s assisted-suicide law.
The Court found the Interpretive Rule invalid after analyzing it under three different principles:
- Auer deference: An agency rule interpreting its own ambiguous regulation may be given substantial deference under Auer v. Robbins, 519 U.S. 452 (1997). The Rule in this case does not deserve such deference because the regulation the Attorney General interpreted simply paraphrases the CSA. Thus, the Interpretive Rule does not bring to bear any special expertise on the Attorney General’s part.
- Chevron deference: An agency rule interpreting an ambiguous statute that the agency is in charge of enforcing may be given deference under Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). The Rule also does not deserve this type of deference. The CSA gives the Attorney General only limited authority, such as the ability to de-license a single physician for illegally trafficking in narcotics. It does not give the Attorney General sweeping authority to criminalize all doctors who follow a State law.
- Skidmore persuasiveness: An agency interpretation is entitled to respect depending upon how persuasive the interpretation. Skidmore v. Swift, 323 U.S. 134 (1944). Here, the Attorney General’s Rule is unpersuasive. It is clear that the CSA was not intended to regulate the practice of medicine generally, which is a power left to the States.
In sum, the CSA was passed to combat drug abuse. Regulation of the medical profession is found elsewhere and would be done in conjunction with the Secretary for Health and Human Services.
Dissenting Opinion (Scalia):
The Attorney General’s Rule should have been accorded deference under both Auer and Chevron. The Attorney General should have the ability to interpret what “legitimate medical purpose” means in the language of the CSA.
Dissenting Opinion (Thomas):
The Court only recently found that the CSA had broad, sweeping powers when effectively invalidating a State’s medical marijuana statute. It is incongruous that the Court now sees the CSA in a strictly limited way.
Gonzales v. Oregon settled the important issue of whether the Federal Government could intervene in a State’s ability to allow death-with-dignity laws. This decision makes it much easier for States to determine their own destiny with regard to enacting assisted suicide laws.