noting that courts owe no deference to an agency’s interpretation of an unambiguous statute
How later courts described this case
- noting that courts owe no deference to an agency’s interpretation of an unambiguous statute
- stating we construe a subsection of a statute in the context of the entire statute
- “[F]ocusing on text does not mean interpreting it hyperliterally or in a vacuum—context matters.”
- concluding an arguably ambiguous statutory term could reasonably be given “only” one meaning when examined in the context of all the statute’s provisions
Written by the judges who cited it.
The opinion
BOLICK, J.,
concurring:
¶ 25 I join entirely the Court’s analysis and outcome. In addition to other arguments rejected by the Court, the Department urged us to apply Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 , 104 S.Ct. 2778 , 81 L.Ed.2d 694 (1984), and defer to its administrative expertise in construing the statute. I write separately only to note that this Court has never expressly considered whether Chevron or its progeny establish standards for administrative deference under Arizona law. I trust that, to the contrary, our constitutional separation of powers remains vibrant, notwithstanding the extent to which the United States Supreme Court has eroded it in the federal context. See Gutierrez-Brizuela v. Lynch, 834 F.3d 1142, 1149-58 (10th Cir. 2016) (Gorsueh, J., concurring).