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No. 19-402October Term 2019Decided Feb 24, 2020Updated Feb 24, 2020

Docket 19-402October Term 2019 (2019–2020)

Baldwin v. United States

This case asks whether a federal agency can adopt a new interpretation of an ambiguous statute that overrides an earlier interpretation by a federal court of appeals.

Case status

Decided · February 24, 2020

Read the opinion (PDF)
Current stage
Decided
Latest event
Decision released Feb 24, 2020
Case Accepted
Arguments
Decision ReleasedFeb 24, 2020
What it's about

This case asks whether a federal agency can adopt a new interpretation of an ambiguous statute that overrides an earlier interpretation by a federal court of appeals. In a tax dispute over 26 U.S.C. § 7502, the Ninth Circuit held that the IRS’s later interpretation displaced the circuit’s older precedent recognizing the common-law mailbox rule.

Question presented

Whether this Court’s decision in National Cable & Telecommunications Ass’n v. Brand X Internet Services, 545 U.S. 967 (2005), should be overruled.

Case path

United States Court of Appeals for the Ninth Circuit / Decision released Feb 24, 2020

Area

Administrative Law

Timing

Decided February 24, 2020

The Court released its decision on February 24, 2020 without hearing oral argument.

Activity

Docket activity2
  • Opinion added: Opinion

    Feb 24, 2020 | Court records

  • Brief added: Petition

    Sep 23, 2019 | Court records

Grounding

Grounding
Primary-source trail available.
Note
Plain-English explainer. Official filings and opinions remain authoritative.
Checked
Jul 25, 2026
Primary materials5