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by granzymes 716 days ago
The question before the Court in this case was whether the FTC has the power to issue substantive rules related to unfair methods of competition. The Court concludes[0] that the FTC does not have that power, and that Section 6(g) of the FTC Act permits the FTC only to issue "housekeeping" rules related to agency organization, procedure, or practice.

That follows from three main statutory and historical clues:

1) Section 6(g) contains no penalty provision—which indicates a lack of substantive force. Other grants of substantive rulemaking specify what happens if regulated entities don't follow the rule.

2) The location of Section 6(g) is suspect. It's the seventh in a list of twelve almost entirely investigative powers, and starts with a grant of organizational power to "from time to time classify corporations". This is hardly where you would expect to find sweeping substantive rulemaking power if Congress had in fact chosen to grant it.

3) The FTC has not historically seen itself as possessing the power to issue substantive rules on unfair methods of competition. Courts are skeptical of agencies discovering latent powers decades later.

Overall, this is exactly what commentators expected to happen. Banning noncompetes may well be good policy, but it's up to the legislature (whether Congress or in individual states) to enact that policy. In addition, nothing in this decision prevents the FTC from using its adjudicatory powers to go after individual examples of noncompetes which it believes are unfair methods of competition.

[0] https://storage.courtlistener.com/recap/gov.uscourts.txnd.38...

2 comments

Thank you for a thoughtful summary of what really happened. So many people are focused on outcomes that they would destroy the plumbing of government to get where they want to be.
For all the talk of a politicized Supreme Court, I'm not so sure that the net result has been to empower authoritarianism, even if it limits their personal liability to later prosecution. Shutting down Chevron principal empowers the Legislature, it seems to me.
Well, they allowed kings to run the nation, that's scary.

But Chevron is about a different project. It's ambition is to fulfill the Federalist Society fantasy of de-governance.

What comes from that isn't direct authoritarianism by government. It's unchecked corporate greed control & influence, with a government maimed and without ability to respond or act. Making rulemaking & regulation impossible, preventing defense of consumers, is the plan for Federalist Society's unchecked economic totalitarianism.

Maybe perhaps possibly we see a legislature better able to wield and use power, after this redefinition of government. But with the shape of the Senate favoring small states >> 10x big states, it seems unlikely that the will to govern will finally get upper hand over the will to de-govern.

Removing Chevron empowers the judiciary, not the legislature. Major questions doctrine and some of the recent cases around it (student loans) have empowered legislature over executive.
I honestly believe the FTC action was a corporate lobbied event. Why? There were various states where campaigns were ongoing to ban noncompetes. The FTC ruling basically derailed them.
Absolutely could have been, it would take months to get them going again.

If only legislators would legislate!