Christensen v. Harris County
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Christensen v. Harris County, 529 U.S. 576 (2000), established the rule that a regulatory agency's interpretation, as set forth in an internal guidance memoranda or other means lacking benefits of the rulemaking procedure, does not qualify for the dispositive force described in Chevron. "Interpretations such as those in ... policy statements, agency manuals, and enforcement guidelines, all of which lack the force of law--do not warrant Chevron-style deference." Id. at 587. See also United States v. Mead Corp., 533 U.S. 218, 234 (2001).