United States v. Mead Corp.

United States v. Mead Corp., 533 U.S. 218 (2001), is a case decided by the United States Supreme Court that addressed the issue of when the Chevron doctrine should be applied.

United States v. Mead Corp.
Argued November 8, 2000
Decided June 18, 2001
Full case nameUnited States v. Mead Corp.
Citations533 U.S. 218 (more)
121 S. Ct. 2164; 150 L. Ed. 2d 292; 2001 U.S. LEXIS 4492
Holding
A tariff classification is not entitled to judicial deference under the Chevron doctrine.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajoritySouter, joined by Rehnquist, Stevens, O'Connor, Kennedy, Thomas, Ginsburg, Breyer
DissentScalia
Laws applied
Customs Act

Background

Mead Corporation challenged a ruling of the US Customs Service that classified its day planners as "diaries, notebooks and address books, bound," which were subject to a tariff.

Issue

Before Mead, it was clear that the Chevron doctrine applied to interpretations adopted in legislative rules and certain formal adjudications, but lower courts differed on whether it also applied to interpretative rules, policy statements, informal adjudications, advisory letters, and amicus briefs. In 2001, the Supreme Court finally began to shed some light on the issue.

In Mead, the issue was whether the court should defer to the US Customs Services' interpretation of the Customs Act, as manifested by the many classification decisions its regional offices made annually. The Court granted certiorari to determine the limits of Chevron deference.

Decision

Justice Souter wrote that "administrative implementation of a particular 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 that the agency interpretation claiming deference was promulgated in the exercise of that authority."[1]

Recognizing that thousands of tariff decisions are issued each year by the 46 regional offices of the U.S. Customs Service, and that each decision has no precedential value, the Court determined that the Chevron Doctrine should not apply.

However, the Court remanded the case for the Court of Appeals for the Federal Circuit to determine whether Customs' classification decision was entitled to deference according to its "power to persuade" under Skidmore v. Swift, 323 U.S. 134 (1944).[2]

Dissent

Justice Scalia was the sole dissenter in the case. Scalia believed that Chevron deference should be applied to all agency decisions that are "authoritative" and so took issue with the Court's reaffirmation of Skidmore, which Scalia called an "anachronism."[3]

See also

References
  1. United States v. Mead Corp., 533 U.S. 218, 226-27 (2001).
  2. Mead Corp., 533 U.S. at 234-39.
  3. Mead Corp., 533 U.S. at 239, 250.
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