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Administrative Law Keyed to Breyer
United States v. Mead Corp.
Citation:
533 U.S. 218 (2001)Facts
The Mead Corporation imported three-ring binders with pages for daily schedules, phone numbers, and addresses, along with calendars, which it marketed as “day planners.” Between 1989 and 1993, U.S. Customs Service classified these planners under a duty-free subheading of the Harmonized Tariff Schedule. In January 1993, Customs changed its position and issued a Headquarters ruling letter classifying the planners as “Diaries…bound” subject to a 4% tariff. After Mead’s protest, Customs issued a more detailed ruling letter maintaining this classification. Customs reasoned that “diary” included books with printed dates for daily memoranda and that the ring-binder format qualified as “bound.” The Federal Circuit rejected Customs’ reasoning, finding that planners were not diaries because they lacked space for extensive notations about past events, and that ring-fastened items did not qualify as “bound” under the tariff schedule.
#Issue:
Does a tariff classification ruling by the United States Customs Service deserve judicial deference under Chevron, or is it entitled only to respect according to its persuasiveness under Skidmore?
#Holding:
No, a Customs tariff classification ruling does not qualify for Chevron deference because there is no indication that Congress intended such rulings to carry the force of law, but it may claim respect under Skidmore according to its persuasiveness.
#Concurring Opinions:
N/A
#Dissenting Opinions:
Justice Scalia argued that the majority’s approach represented an “avulsive change” in judicial review of administrative action. He contended that Chevron established a general presumption that ambiguity in a statute administered by an agency should be resolved by that agency, not the courts. He criticized the majority for creating a confusing “totality of the circumstances” test and predicted that the decision would lead to ossification of statutory law and increased litigation.
#Reasoning and Analysis (Souter):
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