Cite as: 537 U. S. 36 (2002)
Syllabus
where petitioner was headquartered, the Michigan commission levied a fee of $10 per vehicle for the 1992 registration year on petitioner's entire fleet, with payment due on January 1, 1992. After paying the fees in October 1991 under protest, petitioner brought suit in the Michigan Court of Claims seeking a refund of the fees it paid for its Illinois-licensed vehicles after the Single State Registration System came into effect. It alleged that, because Michigan had not "collected or charged" a 1991 registration fee for those trucks, ISTEA's fee-cap provision prohibits Michigan from levying a fee for them. The court granted petitioner summary judgment, and the Michigan Court of Appeals affirmed. The Michigan Supreme Court reversed, concluding that reciprocity agreements are not relevant in determining what fee a State "charged or collected" as of November 15, 1991. Applying Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837, the court determined that the statute unambiguously forbids the ICC's interpretation. Reasoning that the new fee system is based not on the fees collected from one individual company, but on the fee system that the State had in place on November 15, 1991, the court concluded that it must look not at the fees petitioner paid in any given year, but at the generic fee Michigan charged or collected from carriers as of November 15, 1991.
Held: The Michigan Supreme Court erred in holding that, under
§ 14504(c)(2)(B)(iv)(III), only a State's "generic" fee is relevant to determining the fee that was "collected or charged as of November 15, 1991." States may not renounce or modify a reciprocity agreement so as to alter any fee charged or collected as of that date. Because the ICC's interpretation of ISTEA's fee-cap provision is a permissible reading of the statutory language and reasonably resolves ambiguity therein, the ICC's interpretation must receive deference under Chevron, supra, at 843, and the Michigan Supreme Court erred in declining to enforce it. The fee-cap provision does not foreclose the ICC's determination that fees charged under States' pre-existing reciprocity agreements were, in effect, frozen by the new Single State Registration System. The statutory language "collected or charged" can quite naturally be read to mean fees that a State actually collected or charged. The statute can easily be read as the ICC chose, making it unlawful for a State to renounce or modify a reciprocity agreement so as to alter any fee charged or collected as of November 15, 1991. While the Michigan Supreme Court's reading of the statute might be reasonable, nothing in the statute compels that particular result. The fee-cap provision refers not to a "fee system," but to the "fee . . . collected or charged." Under the ICC's rule, where a State waives its registration fee, its "fee . . . collected or
37
Page: Index Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: October 4, 2007