United States v. Haggar Apparel Co., 526 U.S. 380, 4 (1999)

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Cite as: 526 U. S. 380 (1999)

Opinion of the Court

Carter G. Phillips argued the cause for respondent. With him on the briefs were Mark E. Haddad, Ronald W. Gerdes, Gilbert Lee Sandler, Edward M. Joffe, and Marc W. Joseph.*

Justice Kennedy delivered the opinion of the Court.

This case concerns regulations relating to the customs classification of certain imported goods. The regulations were issued by the United States Customs Service with approval of the Secretary of the Treasury. The question is whether these regulations, deemed controlling by the Treasury, are entitled to judicial deference in a refund suit brought in the Court of International Trade. Contrary to the position of that court and the Court of Appeals for the Federal Circuit, we hold the regulation in question is subject to the analysis required by Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837 (1984), and that if it is a reasonable interpretation and implementation of an ambiguous statutory provision, it must be given judicial deference.


Respondent Haggar Apparel Co. designs, manufactures, and markets apparel for men. This matter arises from a refund proceeding for duties imposed on men's trousers shipped by respondent to this country from an assembly plant it controlled in Mexico. The fabric had been cut in the United States and then shipped to Mexico, along with the thread, buttons, and zippers necessary to complete the garments. App. 37-38. There the trousers were sewn and reshipped to the United States. If that had been the full extent of it, there would be no dispute, for if there were

*Briefs of amici curiae urging affirmance were filed for Anhydrides & Chemicals, Inc., et al. by Richard C. King; and for the Customs and International Trade Bar Association by Terence P. Stewart, Bernard J. Babb, Munford Paige Hall II, Rufus E. Jarman, Jr., William D. Outman II, Christopher E. Pey, Melvin Schwechter, David Serko, Sidney N. Weiss, and Sandra Liss Friedman.


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