222
Opinion of the Court
sionally created . . . program necessarily requires the formulation of policy' " (quoting Morton v. Ruiz, 415 U. S. 199, 231 (1974))). If this Court's opinion in Christensen v. Harris County, 529 U. S. 576 (2000), suggested an absolute rule to the contrary, our later opinion in United States v. Mead Corp., 533 U. S. 218 (2001), denied the suggestion. Id., at 230-231 ("[T]he want of" notice and comment "does not decide the case"). Indeed, Mead pointed to instances in which the Court has applied Chevron deference to agency interpretations that did not emerge out of notice-and-comment rule-making. 533 U. S., at 230-231 (citing NationsBank of N. C., N. A. v. Variable Annuity Life Ins. Co., 513 U. S. 251, 256- 257 (1995)). It indicated that whether a court should give such deference depends in significant part upon the interpretive method used and the nature of the question at issue. 533 U. S., at 229-231. And it discussed at length why Chevron did not require deference in the circumstances there present—a discussion that would have been superfluous had the presence or absence of notice-and-comment rulemaking been dispositive. 533 U. S., at 231-234.
In this case, the interstitial nature of the legal question, the related expertise of the Agency, the importance of the question to administration of the statute, the complexity of that administration, and the careful consideration the Agency has given the question over a long period of time all indicate that Chevron provides the appropriate legal lens through which to view the legality of the Agency interpretation here at issue. See United States v. Mead Corp., supra; cf. also 1 K. Davis & R. Pierce, Administrative Law Treatise §§ 1.7, 3.3 (3d ed. 1994).
For these reasons, we find the Agency's interpretation lawful.
III
Walton's second claim is more complex. For purposes of making that claim, Walton assumes what we have just decided, namely, that the statute's "12 month" duration require-
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