Friday, November 15, 2013

United States v. Mead Corp. case brief

United States v. Mead Corp. case brief summary
533 U.S. 218 (2001)

On writ of certiorari to the United States Court of Appeals for the Federal Circuit, petitioner, the United States Customs Service, challenged a refusal by the court of appeals to accord deference to a ruling classifying respondent publisher's day planners as bound diaries under the Harmonized Tariff Schedule of the United States, Subheading 4820.10.20, 19 U.S.C.S. § 1202 (1992).


  • Prior to the ruling, the planners were classified as unbound. 
  • The court held that administrative implementation of a particular statutory provision qualified for deference when it appeared Congress delegated authority to the agency generally to make rules carrying the force of law, and the agency interpretation claiming deference was promulgated in the exercise of that authority. 
  • The ruling at issue failed to qualify, although the possibility that it deserved some deference led the court to vacate and remand. 
  • The delegation gave no indication it delegated authority to issue classification rulings with the force of law. 
  • There was no notice-and-comment practice at the time, and the Custom Service had regarded a classification as conclusive only as between itself and the particular importer only until advance notice of an intended change was given. 
  • Such a ruling could at least seek a respect proportional to its power to persuade under prior case law. 
  • Because the prior case law assessment called for was to be made by the United States Court of Appeals for the Federal Circuit or the Court of International Trade, the court vacated the judgment and remanded for further proceedings.

The judgment was vacated and the case was remanded.

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