Citation. AT&T Corp. v. Iowa Utils. Bd., 525 U.S. 366, 119 S. Ct. 721, 142 L. Ed. 2d 834, 1999 U.S. LEXIS 903, 67 U.S.L.W. 4104, 1991-1 Trade Cas. (CCH) P72,405, 99 Cal. Daily Op. Service 633, 99 Daily Journal DAR 773, 1999 Colo. J. C.A.R. 456, 14 Comm. Reg. (P & F) 1120, 12 Fla. L. Weekly Fed. S 85 (U.S. Jan. 25, 1999)
Brief Fact Summary. The Telecommunications Act of 1996 (Act) fundamentally restructured the local telephone markets: States could no longer enforce laws that impeded competition, and local exchange carriers (LECs) were made obligated to share their network with competitors through unbundled access-a requirement the LECs challenged in this case.
Synopsis of Rule of Law. The reasonableness of an agency’s interpretation depends on its fit with the relevant statute
Issue. Did the FCC have authority to implement pricing and non-pricing provisions of the Telecommunications Act of 1996? Were the Commission’s rules consistent with the Act?
Held. Yes. The grant in Section:201(b) meant what it said: The FCC has rulemaking authority to carry out the provisions of the Act, which included Section:Section:251 and 252, added by the Telecommunications Act of 1996. No. FCC did not adequately consider the “necessary and impair” standards of Section:251(d)(2) when it gave blanket access to these networks, and others, in Rule 319. The Court vacated the Rule 319 because the Commission did not interpret the terms of the statute in a reasonable fashion. Justice Souter, Concurring in Part and Dissenting in Part. Souter agreed that the FCC had authority to interpret the disputed provisions of the Act, and that Chevron deference to the Commission’s reasonable interpretation was owed. Souter disagreed that the Commission was unreasonable in its interpretation of Section:251(d)(2), thinking the Commission reasonably interpreted its duty to consider necessity and impairment.
Discussion. The majority has assumed, thus far, that an interpretation’s reasonableness depends on its fit with the relevant statute. The agency’s reasoning process is generally regulated by a separate doctrine. Chevron is the most controversial doctrine in modernadministrative law.