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United States v. Mead Corporation
| What is deference in the context of the administrative state? Deference, or judicial deference, is a principle of judicial review in which a federal court yields to an agency's interpretation of a statute or regulation. The U.S. Supreme Court has developed several forms of deference in reviewing federal agency actions, including Chevron deference, Skidmore deference, and Auer deference. Learn about state-level responses to deference here. |
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| United States v. Mead Corporation | |
| Reference: 533 U.S. 218 | |
| Term: 2000 | |
| Important Dates | |
| Argued: November 8, 2000 Decided: June 18, 2001 | |
| Outcome | |
| United States Court of Appeals for the Federal Circuit remanded | |
| Majority | |
| Chief Justice William Rehnquist • John Paul Stevens • Sandra Day O'Connor • Anthony Kennedy • David Souter • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer | |
| Dissenting | |
| Antonin Scalia | |
United States v. Mead Corporation is a case decided on June 18, 2001, by the United States Supreme Court. The case narrowed the scope of Chevron deference, which requires a federal court to defer to a federal agency's interpretation of a statute that the agency administers, to only include agency regulations and adjudicatory actions. The case reserved other agency actions for consideration under Skidmore deference, which allows a federal court to yield to an agency's interpretation of a statute administered by the agency according to the agency's ability to demonstrate persuasive reasoning. The case involved the tariff classification of a product imported by the Mead Corporation according to a ruling letter issued by the United States Customs Service.[1][2][3]
In brief: The Mead Corporation had imported day planners duty-free for several years. The Customs Headquarters Office issued a ruling letter that classified the day planners as bound diaries subject to a tariff. The Mead Corporation filed suit and the United States Court of Appeals for the Federal Circuit decided that ruling letters should not be given judicial deference since they are not subject to notice-and-comment rulemaking and do not carry the force of law. The ruling was appealed to the Supreme Court, which vacated and remanded the decision. The Supreme Court's opinion set limits on the application of Chevron deference and, instead, invoked consideration of the ruling letter under Skidmore deference.[2]
Why it matters: The ruling in United States v. Mead Corporation narrowed the scope of application for Chevron deference to agency regulations and adjudicatory actions. Additional agency actions, such as other rulings, guidance, or policy statements, were relegated to consideration under Skidmore deference.[1]
Background
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The Harmonized Tariff Schedule of the United States authorizes the United States Customs Service, through regulations issued by the secretary of the U.S. Department of the Treasury, to establish the rate of duty on imports. These regulations permit the Customs Headquarters Office and any of the 46 port-of-entry customs offices to set tariff classifications for certain imports in the form of ruling letters.[2][3]
The Mead Corporation imported three-ring binders with calendars and other supplemental pages that they described as day planners. After being classified as duty-free for several years, the Customs Headquarters Office issued a ruling letter in 1993 that classified the day planners as bound diaries subject to a tariff. The Mead Corporation filed suit in the Court of International Trade. Summary judgment was granted to the government of the United States, which adopted the reasoning of the Customs Headquarters Office. The Mead Corporation appealed the decision. The United States Court of Appeals for the Federal Circuit reversed the order and found that ruling letters should not be granted judicial deference. Unlike agency regulations, which are binding rules that are developed with opportunities for public feedback during the rulemaking process, ruling letters are not vetted through rulemaking and do not carry the force of law. The court of appeals' decision was appealed to the Supreme Court.[2][3]
Oral argument
Oral arguments were held on November 8, 2000. The case was decided on June 18, 2001.[2]
Decision
The Supreme Court decided 8-1 to vacate and remand the lower court's ruling. The majority opinion was written by Justice David Souter and joined by Chief Justice William Rehnquist, John Paul Stevens, Sandra Day O'Connor, Anthony Kennedy, Clarence Thomas, Ruth Bader Ginsburg, and Stephen Breyer. Justice Antonin Scalia dissented.[3]
Opinions
Opinion of the court
- See also: Chevron deference and Skidmore deference
Writing for the majority, Justice David Souter argued that the ruling letters did not carry the same weight as regulations since they did not undergo notice-and-comment rulemaking, among other considerations. Thus, Souter claimed that the ruling letters did not qualify for Chevron deference, which requires a federal court to yield to an agency's interpretation of a statute that the agency administers. The ruling letters did, however, qualify for consideration under Skidmore deference, which allows a federal court to yield to a federal agency's interpretation of a statute administered by the agency according to the agency's ability to demonstrate persuasive reasoning.[1]
| “ | To agree with the Court of Appeals that Customs ruling letters do not fall within Chevron is not, however, to place them outside the pale of any deference whatever. Chevron did nothing to eliminate Skidmore ’s holding that an agency’s interpretation may merit some deference whatever its form, given the “specialized experience and broader investigations and information” available to the agency and given the value of uniformity in its administrative and judicial understandings of what a national law requires.
|
” |
| —Justice David Souter, majority opinion in United States v. Mead Corporation (2001)[1] | ||
Dissenting opinion
Justice Antonin Scalia dissented from the majority and argued that the Supreme Court's decision deviated from the historical understanding of Chevron deference by requiring that statutory ambiguities in congressional delegations of authority to agencies be resolved by the courts rather than by the agencies themselves. He argued that the ruling would result in confusion for lower courts and a potential increase in the use of informal rulemaking by agencies in an effort to qualify for judicial deference in the future. Scalia stated, "There is, in short, no way to avoid the ossification of federal law that today's opinion sets in motion. What a court says is the law after according Skidmore deference will be the law forever, beyond the power of the agency to change even through rulemaking."[1]
Impact
The ruling in United States v. Mead Corporation narrowed the scope of application for Chevron deference to agency regulations and adjudicatory actions. Additional agency actions, such as other rulings, guidance, or policy statements, were relegated to consideration under Skidmore deference.[1]
See also
- Skidmore deference
- Chevron deference
- Deference
- Supreme Court of the United States
- Ballotpedia's administrative state coverage
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Legal Information Institute, "UNITED STATES v. MEAD CORP.," accessed May 18, 2018
- ↑ 2.0 2.1 2.2 2.3 2.4 JUSTIA, "United States v. Mead Corp., 533 U.S. 218 (2001)," accessed May 18, 2018
- ↑ 3.0 3.1 3.2 3.3 Oyez, "United States v. Mead Corporation," accessed May 18, 2018
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
