<P> Under the Supreme Court's ruling in Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803), United States federal courts have the authority to judicially review the statutes enacted by Congress, and declare a statute invalid if it violates the Constitution . But the Constitution sets no express limits on how much federal authority can be delegated to a government agency . Rather, limits on the authority granted to a federal agency occur within the statutes enacted by Congress . It is also worth noting that federal courts are constitutionally of "limited jurisdiction". Congress bestowed on them the authority to adjudicate administrative matters in 1948 . (28 USC sec. 1331 (1948)) </P> <P> Congress amended the Clean Air Act in 1977 to address states that had failed to attain the air quality standards established by the Environmental Protection Agency (EPA) (Defendant). "The amended Clean Air Act required these' non-attainment' States to establish a permit program regulating' new or modified major stationary sources' of air pollution ." During the Carter administration, the EPA defined a source as any device in a manufacturing plant that produced pollution . In 1981, after Ronald Reagan's election, the EPA, which was headed by Anne M. Gorsuch, adopted a new definition that allowed an existing plant to get permits for new equipment that did not meet standards as long as the total emissions from the plant itself did not increase . The Natural Resources Defense Council (NRDC), an environmental protection group, challenged the EPA regulation in federal court, which ruled in the NRDC's favor . Chevron, an affected party, appealed the lower court's decision . </P> <P> The issue facing the Court was what standard of review should be applied by a court to a government agency's own reading of a statute that it is charged with administering . </P> <P> The Court, in an opinion by Justice John Paul Stevens, upheld the EPA's interpretation . A two - part analysis was born from the Chevron decision (called the "Chevron two - step test"), where a reviewing court determines: </P>

As a result of the supreme court's decision in the standard oil case (1915) the