Mead Corp. v. United States
United States Court of Appeals for the Federal Circuit
283 F.3d 1342 (2002)

- Written by Josh Lee, JD
Facts
The Mead Corporation (plaintiff) imported five models of day planners into the United States. The models were similar but had a few differences. All models contained a calendar, a section for daily notes, a section for telephone numbers and addresses, and a notepad. All models used a ringed binder to hold the loose-leaf pages together. The models varied by size, and the larger models also had additional features, such as a daily-planner section, a plastic pouch, and a ruler. The United States Customs Service (customs) (defendant) issued a ruling classifying the day planners as bound diaries under the Harmonized Tariff Schedules of the United States (HTSUS). As a result, the products were subject to a 4 percent tariff. Mead challenged the ruling, arguing that the products should be classified under a different heading for items similar to diaries, which had a zero-rate tariff. Customs issued a more detailed ruling but otherwise rejected the challenge. Mead appealed to the Court of International Trade, which granted summary judgment in customs’ favor. Mead then appealed to the Federal Circuit, which reversed. Customs petitioned the United States Supreme Court for review. The Supreme Court determined that the Federal Circuit failed to apply the Skidmore deference standard to customs’ classification ruling. The Supreme Court therefore remanded the case to the Federal Circuit for reconsideration.
Rule of Law
Issue
Holding and Reasoning (Rader, J.)
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