United States v. Mead Corp.
Citation: 533 U.S. 218 (U.S. Supreme Court, 2001)
Facts
The United States Customs Service classified Mead Corporation’s day planners as “bound diaries” subject to a 4% tariff, reversing its prior classification. This classification was issued as a tariff ruling letter — a letter ruling applicable only to a single importer, issued without notice-and-comment procedures. Mead challenged the classification, and the Court of International Trade and Federal Circuit rejected Chevron deference on the ground that tariff rulings lack the force of law.
Issue
When is an agency’s statutory interpretation entitled to Chevron deference, and what deference standard applies to agency interpretations that do not qualify for Chevron?
Holding
The Supreme Court held that Chevron deference applies only when Congress has delegated to the agency the authority to make rules with the force of law, and the agency’s interpretation was promulgated in the exercise of that authority. Because Customs’ tariff rulings were not issued through notice-and-comment rulemaking or formal adjudication, they did not carry the force of law and did not receive Chevron deference. They were entitled to Skidmore deference — weight proportional to their persuasive power, reasoning, consistency, and the agency’s expertise.
Rule
Chevron deference is not automatic whenever an agency interprets a statute it administers. It applies only where Congress has implicitly or explicitly delegated to the agency authority to make binding legal interpretations, typically exercised through notice-and-comment rulemaking or formal adjudication. Agency interpretations lacking that imprimatur receive Skidmore deference — respect commensurate with their thoroughness, validity of reasoning, and consistency.
Significance
Mead is the leading “Chevron step zero” case — it addresses the threshold question of whether Chevron applies at all before courts proceed to Chevron steps one and two. The decision significantly limits the scope of Chevron by making it dependent on congressional delegation of interpretive authority rather than applying whenever an agency interprets its own statute. Justice Scalia’s influential dissent argued that Mead creates a complicated, unpredictable framework. Mead is now read alongside Loper Bright Enterprises v. Raimondo (2024), which overruled Chevron itself, rendering Skidmore the default deference standard.