## Facts

- The Harmonized Tariff Schedule authorized the U.S. Customs Service to classify imports and set duty rates under rules prescribed by the Secretary of the Treasury.
- Treasury regulations permitted Customs to issue tariff-classification “ruling letters” for particular transactions; the letters bound Customs personnel but applied only to identical goods and could be modified or revoked.
- Mead Corporation imported “day planners,” which Customs had treated as duty-free for several years.
- Customs Headquarters issued a ruling letter reclassifying Mead’s day planners as “bound diaries,” making them subject to duty.
- Mead challenged the ruling in the Court of International Trade, which upheld Customs’ classification.
- The Federal Circuit reversed, concluding the ruling letter did not warrant Chevron deference and giving it no deference.

## Issues

1. Whether Customs tariff-classification ruling letters qualify for Chevron deference as agency interpretations with the force of law.
2. If Chevron does not apply, what level of judicial respect, if any, is owed to such ruling letters under Skidmore.

## Decision

- The Supreme Court held that the ruling letter at issue was not entitled to Chevron deference.
- The Court held the ruling letter could receive Skidmore respect to the extent it was persuasive.
- The Court vacated the Federal Circuit’s judgment insofar as it gave the ruling no deference and remanded for reconsideration under Skidmore.

## Legal Principles

- Chevron deference applies only when (1) Congress delegated to the agency authority generally to make rules carrying the force of law, and (2) the interpretation claiming deference was issued in exercise of that authority.
- The absence of procedures or indicia showing Congress intended the agency action to have the force of law (such as notice-and-comment rulemaking or comparable formal mechanisms) weighs against Chevron deference.
- Even when Chevron does not apply, agency interpretations may merit Skidmore respect depending on their persuasiveness, including factors such as thoroughness, reasoning, and consistency over time.

## Conclusion

The Court limited Chevron’s reach to agency interpretations issued under delegated lawmaking authority and held that Customs classification ruling letters do not meet that threshold, while remaining eligible for Skidmore respect based on their power to persuade.


United States v. Mead Corp., 533 U.S. 218 (2001)