USPS v. PRC, No. 16-1284 (D.C. Cir. 2018)Annotate this Case
The DC Circuit granted the Postal Service's petition for review of the Commission's orders ruling that a mail preparation change constitutes a change in rates if it results "in the deletion of a rate cell" or "in the redefinition of a rate cell if the mail preparation change causes a significant change to a basic characteristic of a mailing." The Commission reaffirmed its earlier decision and held that the Postal Service's mail preparation change constituted a change in rates. The court held that the Commission's new analysis added no discernible clarity to its reasoning and it rested on an unreasonable interpretation of "changes in rates" that "goes beyond the meaning that the statue can bear." The court explained that its 2015 decision found that the Commission may have authority to treat some Postal Service changes in mail preparation requirements as changes in rates, but that such potential authority depended on its articulating and applying a test consistent with the statute. In this case, the Commission's present orders failed to do this and thus the court vacated the orders.