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Constitutional Law Keyed to Choper
United States v. Mead
Citation:
533 U.S. 218 (2001)Facts
Mead Corporation imported “day planners,” which are three-ring binders with pages for daily planning, notes, and addresses. Initially, the U.S. Customs Service classified these items as “other” items that were duty-free under the Harmonized Tariff Schedule. In 1993, Customs changed its position and issued a ruling letter reclassifying the day planners as “bound diaries” subject to a 4% tariff. This ruling letter was not the product of formal adjudication or notice-and-comment rulemaking. Customs issues thousands of such ruling letters each year, which are binding only on the specific transaction at issue and do not have precedential effect. Mead challenged this reclassification, arguing that the ruling letters should not receive judicial deference under Chevron.
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