HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn.
View Official PDFBelow are plain-language sections to help you understand what the Court decided in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn. and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn..
The Supreme Court reviewed whether small refineries could obtain an extension of a renewable fuel exemption after a lapse. The Court found that the statute's use of 'extension' does not require continuous coverage. The decision reversed the Tenth Circuit's ruling that small refineries were ineligible for extensions after lapses.
Holding
The single most important “bottom line” of what the Court decided in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn..
The Court held that a small refinery that previously received a hardship exemption may obtain an 'extension' even if it saw a lapse in exemption coverage in a previous year.
Constitutional Concepts
These are the Constitution-related themes that appear in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn.. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn.
The case involves the interpretation of statutory language and the authority of the EPA to grant exemptions, which falls under administrative law.
Syllabus excerpt (verbatim)Because 'the government is not invoking Chevron' now, the Court declines to consider whether any deference is due.
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Why Judicial Review is relevant to HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn.
The Court reviews the Tenth Circuit's interpretation of the statute and the EPA's decision-making process.
Syllabus excerpt (verbatim)The Tenth Circuit vacated EPA's decisions, concluding that the small refineries were ineligible for an 'extension' under subparagraph (B)(i) because they had allowed previous exemptions to lapse.
Key Quotes
Short excerpts from the syllabus in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn. that support the summary and concepts above.
The plain meaning of 'extension' does not require unbroken continuity.
Subparagraph (B)(i)'s 'at any time' language expressly contemplates exemptions beyond 2013.
The statute's text—and that nowhere commands a continuity requirement.
