United States Postal Service v. Postal Regulatory Commission
400 U.S. App. D.C. 168
| D.C. Cir. | 2012Background
- PAEA requires annual financial reports (39 U.S.C. §3652(a)) analyzing costs, revenues, rates, and service to show compliance.
- PRC issued the 2010 Annual Compliance Determination (ACD) finding Standard Flats rates violated §101(d) cost-apportionment.
- ACD ordered increased cost coverage for Standard Flats until revenues exceeded attributable costs.
- USPS challenged the ACD, arguing §101(d) does not govern ACD determinations and the remedy was arbitrary.
- D.C. Circuit upheld the Commission’s interpretation but remanded for explanation of the remedy’s relation to other products and authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May §101(d) be invoked for market-dominant products in extreme cases? | USPS argues §101(d) cannot govern ACD outcomes for market-dominant products. | PRC contends §3622(c)(14) and related provisions permit applying §101(d) in extreme cases. | Yes, in extreme circumstances the Commission may invoke §101(d). |
| Is the remedy of full cost coverage appropriate and consistent with other products? | USPS argues remedy is inconsistent with other market-dominant products and too stringent. | PRC argues remedy aligns with the overarching goal of cost coverage under §101(d). | Remand for justification of the remedy’s scope and consistency; not decided. |
| Do §3622(c)(14) and §3652(a)(1) permit overriding specific factors with general standards? | USPS contends selective override would overstep statutory structure. | PRC asserts broad standards allow alignment with policy goals and data requirements. | The interpretation is reasonable; remand for explanation of the relation to other standards. |
| Should the court remand to define triggers and rationale for the remedy? | USPS argues for limited, well-defined triggers. | PRC argues no need for further explanation beyond current rationale. | Remand granted to define triggers under §101(d) and justify remedy. |
Key Cases Cited
- Public Citizen, Inc. v. FAA, 988 F.2d 186 (D.C.Cir.1993) (agency must adequately explain its results)
- U.S. Postal Service v. Postal Regulatory Comm'n, 599 F.3d 705 (D.C.Cir.2010) (upheld PRC interpretation of §101(d) and related authorities)