UNITED STATES V. MEAD CORPORATION
533 U.S. 218 (2001)
NATURE OF THE CASE: This was a dispute over judicial deference on a tariff
classification. This was an appeal from an order of the Federal Circuit which reversed a
ruling of the Court of International Trade.
FACTS: Under 19 U.S.C. 1500(b), Customs shall under rules and regulations prescribed by
the Secretary of the Treasury fix the final classification and rate of duty applicable to
merchandise. The Secretary provides for tariff rulings before the entry of goods by
regulations authorizing ruling letters setting tariff classifications for particular
imports. This ruling letter represents the official position of the Customs Service. A
ruling letter is to be applied only with respect to transactions involving articles
identical to the sample submitted or to the articles whose description is identical to the
description set forth in a ruling letter (177.9(b)(2)). A letter is subject to modification
or revocation without notice to any person to whom the letter was addressed (177.9(c)). The
regulations clearly state that no person should rely on such a letter or assume that the
principles in a letter will be applied in any other transaction. Any of the 46 Customs
offices may issue ruling letters. Most letters do not have any reasoning attached but some
do set out a rationale in some detail. Mead imports day planners. Between 1989-1993 Customs,
treated day planners under the “other” category of items in subheading 4820.10 and they were
thus free of duty. Customs decided to change that position in 1993 and reclassified Mead’s
products as bound diaries subject to a tariff. Mead protested and a more detailed letter was
issued but never published. The letter considered the two definitions of diary from the
dictionary and concluded that Mead’s products were bound diaries. Mead (P) challenged this
classification and the Court of International Trade affirmed. The Federal Circuit reversed
holding that the letter was not entitled to Chevron deference because it was not issued
after notice and comment rulemaking.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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