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A78 - Deference in Transition: Federal Agency Discretion in Post-Chevron Era Administration
This research examines the institutional transformation of the Supplemental Nutrition Assistance Program (SNAP), utilizing Punctuated Equilibrium Theory and framing the 2024 overturning of Chevron deference as a defining punctuation event within the American social safety net.
A78 - Deference in Transition: Federal Agency Discretion in Post-Chevron Era Administration
Mentor: Sarah Larson, Ph.D.
This research examines the institutional transformation of the Supplemental Nutrition Assistance Program (SNAP), utilizing Punctuated Equilibrium Theory and framing the 2024 overturning of Chevron deference as a defining punctuation event within the American social safety net. For decades, the program operated under a stable administrative equilibrium where the United States Department of Agriculture (USDA) utilized broad regulatory discretion to navigate statutory ambiguities, maintaining a period of path-dependent, incremental adaptation. However, the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo (2024) fundamentally changed this policy monopoly by replacing Chevron with the more lenient Skidmore standard, which requires courts to exercise independent judgment rather than deferring to agency expertise. Utilizing Punctuated Equilibrium Theory, this analysis argues that this judicial shock, coupled with the restrictive mandates of the One Big Beautiful Bill Act (OBBBA), disrupted the long-standing administrative stasis and triggered a period of rapid policy contraction. The findings indicate that the loss of deference has paralyzed agency discretion, replacing flexible poverty alleviation with rigid, compliance-heavy enforcement and heightened administrative burdens. This abrupt shift from a stable landscape to a restrictive regime is evidenced by a significant collapse of the safety net, resulting in the loss of 3.3 million SNAP participants within a single year.