United States Postal Service v. Postal Regulatory Commission
395 U.S. App. D.C. 122
| D.C. Cir. | 2011Background
- PAEA caps rate increases for market-dominant products at CPI-U changes; ex ante safety valve permits expedited above-cap adjustments for extraordinary/exceptional circumstances.
- Postal Service sought exigent rate increases in 2010 citing recession-driven mail-volume declines; Commission denied for not tying increases to the exigency.
- Commission held “due to” requires causation but rejected a strict dollar-for-dollar nexus; remanded to determine the necessary degree of causation.
- Court applies Chevron deference, finds “due to” plain meaning requires causation; remand to address Chevron step 2 for closeness of nexus.
- Regulatory framework: CPI-U cap; regulatory procedures under 39 C.F.R. pt. 3010; above-cap adjustments must be reasonable, equitable, and necessary.
- Final disposition: deny Postal Service petition in part (Chevron step 1 upheld) but grant in part (step 1 rejected strict nexus) and remand for step-2 analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 'due to' require strict nexus to the exigentcircumstance? | Postal Service argues no strict nexus; must be caused by exigency. | Commission requires a causal link; no need for dollar-for-dollar match. | No strict match required; remand for step-2 causation standard. |
| How close must the causal connection be between exigency and proposed increase? | Nexus need not mirror exact revenue loss. | Nexus must be tightly tied to exigency impact. | Chevron step-2 analysis required to define closeness. |
| Is Chevron step 1 limited to plain meaning, or may step 2 apply? | Plain meaning suffices to require causation. | Ambiguity permits step-2 construction. | Court proceeds to Chevron step 2 for ambiguous nexus. |
Key Cases Cited
- Kimber v. Thiokol Corp., 196 F.3d 1092 (10th Cir.1999) (explains broad meanings of 'due to' in causation)
- Adams v. Director, OWCP, 886 F.2d 818 (6th Cir.1989) ('due to' can mean 'partly due to' in causation)
- Peter Pan Bus Lines, Inc. v. Fed. Motor Carrier Safety Admin., 471 F.3d 1350 (D.C.Cir.2006) (Chevron step 2 deference when statute is ambiguous)