Stoel Rives Summer Associate Jessica Wright co-authored this post.
In a landmark decision on July 1, 2024, the Supreme Court ruled that the six-year statute of limitations for facial challenges to agency regulations under the Administrative Procedure Act (APA) begins when the final agency action injures a plaintiff, not when the regulation is issued. This ruling, from Corner Post v. Board of Governors of the Federal Reserve System, overturns the prior understanding that the limitations period started with the rule’s effective date. The 6-3 decision, split along ideological lines, allows businesses and other entities more time to challenge longstanding regulations. This change is expected to significantly impact the administrative law landscape, leading to more regulatory challenges, and altering how agencies draft and enforce rules. Read more about the implications of this decision and how it affects environmental and other regulatory fields on the stoel.com website.