Goat & Sheepskin Import Co. v. United States

Background

An importer challenged customs officials and a board of appraisers who classified a fuzzy growth on certain sheepskins as wool and charged duty. The uncontradicted evidence showed the substance was commercially known as Mocha hair, was mostly dead hair or kemp, could not be carded or spun like wool, and was bought and sold across the country as Mocha hair rather than wool. Lower courts and the appraisers had treated it as wool and assessed duty.

Reasoning

The central question was whether the word “wool” in the tariff law should include this Mocha hair. The Court said classification should follow commercial designation and use, not just the animal the fiber came from. Because the hair lacked wool’s characteristics, had no common use as wool, and was widely known in commerce as Mocha hair, it should not be taxed as wool. The Court rejected the government’s argument that any growth on a wool-bearing sheep automatically counts as wool and concluded the hair should be classified with the skin in the free list.

Real world impact

The decision reverses the lower courts and directs the Circuit Court to proceed consistent with this ruling. Importers of Mocha hair will not face wool duties when the classification follows this opinion. Customs officials and merchants must look to how goods are known and used in the market when deciding tariff labels, not only to the animal species.

Dissents or concurrances

Not applicable; one Justice (Moody) took no part in the decision.