United States v. Mead Corp.

Background

Mead Corporation is a company that imports three‑ring day planners. For years Customs treated those planners as "other" and free of duty, but in 1993 Customs Headquarters reclassified them as "diaries, bound" subject to a 4% tariff. Customs issued a carefully reasoned ruling letter. Mead protested, sued in the Court of International Trade, which adopted Customs's reasoning. The Federal Circuit reversed, refusing to give the ruling Chevron deference, and the case reached this Court to resolve deference rules.

Reasoning

The Court addressed whether tariff classification letters deserve Chevron deference — judicial deference given when Congress clearly meant an agency's rule to have the force of law. The Court concluded these particular Customs rulings do not qualify for Chevron because Congress did not show an intent to make such letters binding beyond the parties, and because rulings are issued widely, without notice-and-comment, and can be modified. Nonetheless, the Court held such rulings may get Skidmore deference — respect based on how persuasive, thorough, consistent, and expert the agency's reasoning is. The Court therefore vacated the judgment and remanded for the lower courts to apply Skidmore factors.

Real world impact

The decision changes how courts review many Customs classifications and similar informal agency rulings. Importers cannot assume a ruling letter will carry Chevron's binding force, but well-reasoned letters can still influence courts. The opinion notes Customs issues thousands of rulings from many offices and that a 1993 statutory change added notice-and-comment for certain modifications after this case arose. The Supreme Court's ruling is procedural about review standards, not a final ruling on Mead's planners' tariff.

Dissents or concurrances

Justice Scalia dissented, arguing for retaining Chevron's presumption of agency authority and warning that the Court's approach will create confusion, encourage more rulemaking, and risk ossifying law.