United States v. Mead Corp.

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United States v. Mead Corp.

Argued November 8, 2000
Decided June 18, 2001

Full case name:	United States v. Mead Corp.

Citations:	533 U.S. 218

Holding

Court membership

Chief Justice: William Rehnquist
Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer

Case opinions

Majority by: Souter

United States v. Mead Corp., 533 U.S. 218 (2001), was a case heard before the United States Supreme Court.

United States v. Mead Corp revolved around the issue of when and where the Chevron Doctrine could be applied.

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

In Mead, it was questioned whether the court should defer to the U.S. Customs Services interpretation of the Customs Act, as manifested through the many classification decisions it regional offices made annually. Recognizing that thousands of such decisions are issued each year by the 46 regional offices, and that each decision has no precedential value, the court determined that the Chevron Doctrine should not apply.

With regard to the test applied in order to arrive at this conclusion, the court stated:

“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 authority."’