United States v. Mead Corp.
Supreme Court
533 U.S. 218 (2001)
U.S. Customs classified tariffs on imported goods through 'ruling letters' issued without notice-and-comment rulemaking and subject only to independent review by the Court of International Trade (CIT). After treating Mead Corporation's (plaintiff's) imported day planners as duty-free for several years, Customs issued a ruling letter in 1993 reclassifying them as bound diaries subject to a 4 percent tariff. The CIT granted summary judgment for the government, adopting Customs's reasoning, but the Federal Circuit reversed, giving the ruling letter no deference at all and rejecting Customs's classification reasoning. The Supreme Court granted certiorari to decide how much deference such agency rulings deserve.
Whether, even if an agency's interpretation of a statute is not entitled to deference under Chevron, the interpretation may still be entitled to deference under Skidmore according to its persuasiveness.