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United States v. Mead Corporation

United States Supreme Court
533 U.S. 218 (2001)


Congress passed legislation providing that the United States Customs Service shall fix the final classification and rate of duty applicable to imported merchandise pursuant to rules and regulations prescribed by the Secretary of the Treasury. Under these regulations, the Headquarters Office or any port-of-entry customs offices may issue a “ruling letter” to indicate the amount of money that an importer owes for the importation of specific goods into the United States. A ruling letter is binding on all Customs Service personnel until modified or revoked, and it may be modified or revoked without notice to any person, except the importer to whom it was addressed. No person other than the recipient of the ruling letter may rely on the letter or assume that the principles of the ruling will be applied to another transaction. The Headquarters Office issued a ruling letter classifying “dayplanners” imported by the Mead Corporation (Mead) (plaintiff) as “diaries” for the purposes of assessing a tariff. Mead filed suit against the United States (defendant), challenging the letter in the Court of International Trade (CIT). The CIT affirmed the ruling. The court of appeals then reversed CIT’s decision. In reaching its decision, the appellate court declined to apply the type of judicial deference called for by Chevron U.S.A. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), because the ruling letter was not issued in accordance with notice and comment rulemaking requirements. The United States Supreme Court granted certiorari to consider the limits of Chevron deference owed to administrative practice in applying a statute.

Rule of Law

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Holding and Reasoning (Souter, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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