| United States v. Mead Corp. | ||||||
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Supreme Court of the United States |
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| Argued November 8, 2000 Decided June 18, 2001 |
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| Full case name | United States v. Mead Corp. | |||||
| Holding | ||||||
| A tariff classification is not entitled to judicial deference under the Chevron doctrine. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Souter, joined by Rehnquist, Stevens, O'Connor, Kennedy, Thomas, Ginsburg, and Breyer | |||||
| Dissent | Scalia | |||||
| Laws applied | ||||||
| Customs Act | ||||||
United States v. Mead Corp., 533 U.S. 218 (2001), was a case heard before the United States Supreme Court, which revolved around the issue of when and where the Chevron Doctrine could be applied.
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Mead Corporation challenged a ruling of the United States Customs Service classifying its day planners as "diaries, notebooks and address books, bound," which were subject to a tariff.
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 its regional offices made annually. The Court granted certiorari to determine the limits of Chevron deference.
The court, speaking through Justice Souter, held 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 a determination of whether the more limited deference of Skidmore v. Swift, 323 U.S. 134 (1944) should be applied to the decision.[2]
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 thus took issue with the Court's reaffirmation of Skidmore, which Scalia called an "anachronism."[3]
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