Opinion of the Court
mining the proper classification of goods. 127 F. 3d, at 1462; see also Rollerblade, Inc. v. United States, 112 F. 3d 481, 483 (CA Fed. 1997); Universal Elecs. Inc. v. United States, 112 F. 3d 488, 491-493 (CA Fed. 1997). The whole point of regulations such as these, however, is to ensure that the statute is applied in a consistent and proper manner. Deference to an agency's expertise in construing a statutory command is not inconsistent with reaching a correct decision.
The analysis of a regulation's application in any particular case, of course, may disclose an imprecise or imperfect implementation of the statute. "One can doubtless imagine questionable applications of the regulation that test the limits of the agency's authority." Babbitt v. Sweet Home Chapter, Communities for Great Ore., 515 U. S. 687, 714 (1995) (O'Connor, J., concurring). In the process of considering a regulation in relation to specific factual situations, a court may conclude the regulation is inconsistent with the statutory language or is an unreasonable implementation of it. In those instances, the regulation will not control. Under Chevron, if a court determines that "Congress has directly spoken to the precise question at issue," then "that is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress." 467 U. S., at 842-843. If, however, the agency's statutory interpretation "fills a gap or defines a term in a way that is reasonable in light of the legislature's revealed design, we give [that] judgment 'controlling weight.' " NationsBank of N. C., N. A. v. Variable Annuity Life Ins. Co., 513 U. S. 251, 257 (1995) (quoting Chevron, supra, at 844).
A statute may be ambiguous, for purposes of Chevron analysis, without being inartful or deficient. The present case exemplifies the familiar proposition that Congress need not, and likely cannot, anticipate all circumstances in which a general policy must be given specific effect. Here Congress has authorized the agency to issue rules so that the tariff statutes may be applied to unforeseen situations andPage: Index Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: October 4, 2007