That is a factually inaccurate description of the role of federal agencies under Chevron deference. Chevron deference was a legal doctrine that required courts

That is a factually inaccurate description of the role of federal agencies under Chevron deference. Chevron deference was a legal doctrine that required courts to defer to reasonable agency interpretations of ambiguous statutes, not a mechanism that allowed career civil servants to unilaterally create criminal laws. Federal agencies could only issue regulations within the authority explicitly delegated by Congress, and these regulations were subject to judicial review, public notice-and-comment periods, and Congressional oversight.