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Judicial deference to executive statutory interpretation -- a doctrine now commonly associated with the Supreme Court's decision in Chevron v. Natural Resources Defense Council -- is one of the central principles in modern American public law. Despite its significance, however, the doctrine's origins and development are poorly understood. The Court in Chevron claimed that the roots of judicial deference stem from statutory interpretation cases dating to the early nineteenth century. Others, by contrast, have sought to locate Chevron's doctrinal roots in judicial review's origins in the writ of mandamus. According to the standard narrative, courts in the pre-Chevron era followed a multifactor and ad hoc approach to issues of judicial deference; there was little theory that explained the body of cases; and the holdings and reasoning of the cases were often contradictory and difficult to rationalize. This Article challenges the standard account. It argues that the Supreme Court in Chevron, and scholarly commentators since, have misidentified nineteenth-century statutory interpretation cases applying canons of construction \"respecting\" contemporaneous and customary interpretation as cases deferring to executive interpretation as such. It further argues that, although the standard for obtaining a writ of mandamus was central to judicial review in the early Republic, statutory developments in the latter half of the nineteenth century (significantly, the enactment of general federal-question jurisdiction in 1875) ultimately mooted the relevance of that standard. Finally, it discusses the intellectual challenges to the traditional interpretive framework beginning in the early twentieth century; the Supreme Court's embrace of these intellectual challenges in the early 1940s; and Congress's attempt in the Administrative Procedure Act's (APA) standard-of-review provision to reject the Court's interpretive experimentation and corresponding deviation from the traditional canons. The Article thus seeks to establish -- contrary to the suggestion in Chevron and recent cases -- that there was no rule of statutory construction requiring judicial deference to executive interpretation qua executive interpretation in the early American Republic. And it contends that the governing statute of administrative law -- the APA -- was intended to codify the traditional interpretive approach and to reject the experimentation of the 1940s Court. Taken together, these conclusions cast doubt on much of the received wisdom on the doctrinal basis for the rule announced in Chevron. [web URL: http://www.yalelawjournal.org/article/the-origins-of-judicial-deference-to-executive-interpretation]

San Francisco-based Chevron Corp., the fourth-largest U.S. oil company, said its fuel-sales business was hurt this year by refinery problems in California that since have been addressed. Chevron's branded gasoline sales have risen 5 percent from last year, while sales from convenience stores are expected to rise 26 percent. Operating costs have been reduced almost 40 cents a barrel, Chevron said. Chevron's second-quarter earnings fell 22 percent because refinery accidents reduced fuel sales.

Chevron Corp. has found a clean supply of gas and won't need to sell fuel that doesn't meet the state's strict air-quality standards. Chevron notified the state Air Resources Board Tuesday that it would no longer need a variance issued by the board last month, which allowed the company to sell so-called \"dirty gas\" until Aug. 30.

San Francisco-based Chevron Corp. now estimates it will cut at least 2,700 jobs by mid-2000, an increase of 200 jobs over its last estimate only six weeks ago and three times more than it said in December. \"We'll probably have a more accurate figure toward the end of this year,\" said spokeswoman Dawn Soper, who stressed that the restructuring was ongoing. \"And 2,700 is a a rough estimate at this point, a round number. Exactly where it's going to end up, we don't know.\"

San Francisco-based Chevron Corp. now estimates it will cut at least 2,700 jobs by mid-2000, an increase of 200 jobs over its last estimate only six weeks ago and three times more than it said in December. \"We'll probably have a more accurate figure toward the end of this year,\" said spokeswoman Dawn Soper, who stressed that the restructuring was ongoing. \"And 2,700 is a a rough estimate at this point, a round number. Exactly where it's going to end up, we don't know.\"

Supervisor Gavin Newsom on Monday asked the city attorney to draft legislation that would force Chevron to post signs at stations selling nonconforming gas. The state Air Resources Board granted Chevron permission last month to sell a limited supply of gas in the Bay Area and in other areas that is more polluting than the fuel normally sold in the state. Chevron spokeswoman Dawn Soper said it is Chevron's hope not to sell the higher-polluting gas. The Air Resources Board said Chevron could sell the nonconforming gas for a 45-day period, starting July 16, but not in regions where air pollution already is high, such as Sacramento and Los Angeles.

San Francisco-based Chevron said it's the first oil company to have a venture-capital unit that invests in new technology. It said Chevron Technology Ventures will work with selected venture capital firms, such as Arch Venture Partners and Ampersand Ventures, as well as make investments independently.

In the wake of Tuesday's announcement of Exxon Corp. agreeing to acquire Mobil Corp. for $82.8 billion, San Francisco-based Chevron said it wouldn't talk about its plans for the future or whether it was in negotiations with other oil and gas operators. But Chevron spokeswoman Dawn Soper said, \"We look at things constantly. Selling assets and acquiring assets is part of our business.\" Yet Soper hastened to add that the megamerger trend of the past few years might not be right for Chevron.

Now, the company says it will cut nearly 600 jobs in the Bay Area alone, according to Mike Libbey, Chevron spokesman. Libbey said Chevron's original estimate of 1,000 job cuts was revised mainly because of a worldwide drop in oil prices. He also said the company had cut 21,000 jobs since 1991, averaging about 3,000 per year. At the end of 1998, Chevron employed 33,676 people worldwide. Libbey said Tuesday's announced job cuts would be the last of the year. The latest job cuts reflect the pressure on Chevron to reduce costs after the failed talks with Texaco, analysts said. Acquisitions such as Exxon Corp.'s $85 billion buyout of Mobil Corp. could leave Chevron facing bigger rivals with lower costs to find and process oil.

In the latest blow to San Francisco's corporate image, Chevron Corp., the nation's fourth-largest oil company, says it plans to sell its Market Street headquarters and move as many as 1,000 employees to the East Bay. The cost-cutting move, which is expected to be completed by the end of next year, will leave about 500 Chevron workers, including top executives, in San Francisco. The company will continue to be headquartered in The City. \"We must continue to reduce non-essential costs and capital to fund our attractive growth prospects,\" [Dave] O'Reilly said in a statement. \"Consolidating many of our San Francisco employees into our offices in the East Bay makes good economic sense.\"