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Mead Doctrine The Supreme Court narrowed the scope of when Chevron deference is applied to agency actions in this 2001 case, US v. Mead Corp., 533 U.S. 218, 121 S. Ct. 2164 (2001). This decision held that "administrative implementation of a particular statutory provision qualifies for Chevron deference when it appears that Congress delegated authority to the agency generally to make rules carrying the force of law, and that the agency interpretation claiming deference was promulgated in the exercise of that authority." The importance of this holding is that even if an agency action fails to qualify for Chevron deference, the agency action may still be subject to the lesser Skidmore deference based on the agency's own persuasiveness. (See Chevron U.S.A., Inc v. NRDC, 467 U.S. 837 (1984)).
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