 Gorsuch has called for reconsideration of "Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc." (1984), in which the Supreme Court instructed courts to grant deference to federal agencies' interpretation of ambiguous laws and regulations.In "Gutierrez-Brizuela v. Lynch" (2016), Gorsuch wrote for a unanimous panel finding that court review was required before an executive agency could reject the circuit court's interpretation of an immigration law.Alone, Gorsuch added a concurring opinion, criticizing "Chevron" deference and "National Cable & Telecommunications Ass'n v. Brand X Internet Services" (2005) as an "abdication of judicial duty", writing that deference is "more than a little difficult to square with the Constitution of the framers' design".