United States v. Mead Corp.

121 S. Ct. 2164 (2001) ; Clearinghouse Number: 53894

Description

Supreme Court Holds That Administrative Ruling Not Subject to Deference Under Chevron May Claim Respect According to Its Persuasiveness

Abstract

The Supreme Court held that administrative implementation of a particular statutory provision qualified for Chevron deference when Congress delegated authority to an agency to make rules carrying the force of law, and the agency interpretation claiming deference was promulgated in the exercise of such authority. Respondent imports day planners, which are three-ring binders with pages for daily schedules, phone numbers, and addresses. After classifying the planners as duty-free for several years, Customs Headquarters Office issued a ruling letter classifying them as bound diaries subject to tariff. Respondent filed suit in the Court of International Trade, which granted the government summary judgment. Reversing that court, the Federal Circuit found that ruling letters should not be treated like customs regulations, which receive the highest level of deference under Chevron U.S.A. Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984), because they are not preceded by notice and comment under the Administrative Procedure Act, do not carry the force of law, and are not intended to clarify importers’ rights and obligations beyond the specific case. Vacating and remanding, the Supreme Court held that a customs ruling letter had no claim to Chevron deference but that, under Skidmore v. Swift & Co., 323 U.S. 134 (1944), it is eligible to claim respect according to its persuasiveness. The Court found that, where Congress explicitly left a gap for an agency to fill, it expressly delegated authority to the agency to elucidate a specific statutory provision by regulation, and any ensuing regulation is binding unless procedurally defective, arbitrary, and capricious or manifestly contrary to the statute. Even in the absence of an express delegation of authority on a particular question, agencies charged with applying a statute must make all sorts of interpretive choices, and, while not all of these choices bind judges to follow them, they may influence courts facing questions the agencies have already answered. The Court found that the weight accorded to an administrative judgment would depend upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors that give it power to persuade, if lacking power to control.

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Docket Date
2001-06-18 00:00:00+00:00

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