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United States v. Mead Corp.

Supreme Court of the United States · 2001 · Constitutional Law

Administrative LawJudicial DeferenceChevronSkidmoreChevron deferenceSkidmore deferenceagency interpretationforce of law

Facts

Customs issues tariff classification ruling letters for particular imports under regulations adopted by the Treasury Secretary. Mead imported day planners, and after previously classifying such goods as duty-free under the "other" subheading, Customs in 1993 issued a Headquarters ruling classifying Mead's planners as "Diaries . . . , bound," which carried a tariff. The Headquarters letter gave a reasoned explanation based on dictionary definitions of "diary" and explanatory notes regarding what counts as "bound." Customs ruling letters are not generally issued through notice-and-comment procedures, may be modified or revoked, and are binding only with respect to the specific transaction or identical goods described.

Issue

Whether a tariff classification ruling letter issued by the United States Customs Service is entitled to Chevron deference. If not, whether such a ruling may still receive some judicial respect under Skidmore.

Rule

Administrative implementation of a statutory provision qualifies for Chevron deference when it appears that Congress delegated authority to the agency generally to make rules carrying the force of law and the agency interpretation claiming deference was promulgated in the exercise of that authority. When Chevron does not apply, an agency interpretation may still receive respect under Skidmore to the extent it has the power to persuade, considering factors such as thoroughness, validity of reasoning, consistency, formality, and expertness.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Federal Product Safety Bureau administers a federal consumer-labeling statute. Congress authorized the Bureau to issue regulations, and the agency has used notice-and-comment rulemaking for some matters, but a regional office in Phoenix also sends thousands of informal classification emails each year deciding whether particular products fall within statutory categories; those emails bind only the requesting manufacturer unless later changed.

A court reviews one of the Phoenix emails interpreting an ambiguous statutory term. What level of deference is most appropriate?

Explanation. Chevron applies only when Congress delegated authority to make rules carrying the force of law and the agency interpretation was issued in exercising that authority. An informal, transaction-specific interpretation issued in large numbers from dispersed offices, binding only the requester and subject to later change, does not show lawmaking force. But the interpretation may still receive Skidmore weight based on its persuasiveness, expertise, and reasoning.