## Facts

- Oregon enacted the Death With Dignity Act, which, subject to specified safeguards, immunizes state-licensed physicians from state civil and criminal liability for prescribing or dispensing lethal medication to terminally ill patients who request it.
- The medications used under the Act include Schedule II controlled substances regulated under the federal Controlled Substances Act (CSA).
- In 2001, the U.S. Attorney General issued an Interpretive Rule stating that prescribing controlled substances for physician-assisted suicide is not a “legitimate medical practice” and is unlawful under the CSA.
- The Rule asserted that physicians who prescribed such drugs pursuant to Oregon law risked loss of their federal controlled-substances registrations.
- Oregon and other plaintiffs sued in federal district court; the court permanently enjoined enforcement of the Rule.
- The Ninth Circuit invalidated the Rule, concluding the CSA did not clearly authorize the Attorney General to convert conduct authorized by Oregon medical law into a federal offense.
- The Supreme Court granted certiorari to determine whether the CSA authorized the Attorney General’s action.

## Issues

1. Whether the CSA authorizes the U.S. Attorney General to prohibit physicians from prescribing controlled substances for physician-assisted suicide when state law permits the practice.
2. Whether the Attorney General’s Interpretive Rule was entitled to administrative deference as an interpretation of the CSA or related regulations.

## Decision

- The Supreme Court affirmed the Ninth Circuit in a 6–3 decision.
- The Court held the CSA does not authorize the Attorney General to categorically deem physician-assisted suicide an illegitimate medical purpose and thereby prohibit prescriptions written in compliance with Oregon law.
- The Court declined to apply Auer or Chevron deference to the Interpretive Rule.
- The Court treated the dispute as one of statutory interpretation and agency authority, not as a decision about the constitutionality or morality of assisted suicide.

## Legal Principles

- The CSA’s primary aim is to control and prevent drug abuse and illicit controlled-substance trafficking, not to set general standards for medical practice.
- Agency authority under the CSA is limited to powers granted by Congress; a claim of sweeping power to define legitimate medical practice nationwide requires clear statutory support.
- Auer deference is inappropriate where a regulation merely paraphrases the statute and the agency’s “interpretation” would effectively control statutory meaning rather than clarify regulatory detail.
- Chevron deference does not apply when the agency asserts authority outside the domain Congress delegated (here, broad judgments about medical practice rather than drug enforcement).
- In areas traditionally regulated by states, federal statutes are read not to displace state authority absent a clear congressional statement.

## Conclusion

The Court held that the CSA did not empower the Attorney General to override Oregon’s physician-assisted suicide regime by declaring such prescriptions categorically illegitimate under federal controlled-substances law, and it invalidated the Interpretive Rule as beyond the authority Congress granted.


Gonzales v. Oregon, 546 U.S. 243 (2006)