Tobacco companies are not the only beneficiaries of the U.S. Supreme Court’s March 21 ruling striking down the Food and Drug Administra-tion’s tobacco regulations.

FDA v. Brown & Williamson , No. 98-1152, also promises relief to other victims of over-zealous agency regulation whose statutory challenges too often founder on simplistic readings of Chevron U.S.A. Inc v. Natural Resources Defense Council (1984).

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