Waite v. MacY

Background

Importers of tea sued a customs board known as the Tea Board to stop it from applying a regulation that rejects tea whenever any coloring matter is detected. The law in question requires customs to compare imported tea to official standards for purity, quality, and fitness for consumption and allows retention only when a tea is found inferior. An examining test used by the board rubs powdered tea on semi-glazed paper and, if any coloring appears, sends the smear for chemical analysis and then rejects the tea. The disputed shipment was far cleaner and worth about four times as much as the official standard sample, but it contained nine to nineteen parts per million of Prussian blue, which the courts found not to be harmful. The District Court dismissed the importers’ bill, the Circuit Court of Appeals reversed and issued an injunction, and the Supreme Court affirmed that injunction.

Reasoning

The Court asked whether the regulation properly interpreted the statute’s limits. It concluded the statute only allowed exclusion when tea is inferior in overall purity, quality, or fitness to the standard, not when a single innocuous trace substance is present. The regulation made any detectable coloring an absolute ground for exclusion, which the Court found to exceed the statute. Given that the challenged tea was otherwise superior to the standard and the dye harmless in the amounts found, the regulation could not lawfully be applied to exclude it. The importers therefore won relief, and the injunction was justified.

Real world impact

The decision prevents the board from using an absolute-dye rule to keep out tea that otherwise meets standards. Customs officials and the Treasury must assess tea according to the statutory criteria as a whole, and agencies cannot enforce a regulation that singles out a harmless trace as automatically making tea inferior. The injunction protects these importers and similar shipments from exclusion under this test.