Abstract
Auers holding confirmed that Seminole Rock deference had survived Chevron and expanded the application of Auer deference to an interpretation arrived at informally and during litigation. Since deciding Auer, the Court has narrowed the doctrine twice. [...]the Court concluded that Auer deference is unwarranted when an agency's interpretation would "impose potentially massive liability.. The Board held that relevant included only documents that were relevant to the diagnosis of PTSD, the underlying issue in Kisor's claim for benefits. Because Kisor presented documents with his second claim that related to the timing of his injury rather than the nature of his injury, the documents were not relevant. [...]the Board denied Kisor's claim for an earlier effective date.