What follows is an opinion from the Supreme Court of the United States. Your task is to identify the court whose decision the Supreme Court reviewed. If the case arose under the Supreme Court's original jurisdiction, note the source as "United States Supreme Court". If the case arose in a state court, note the source as "State Supreme Court", "State Appellate Court", or "State Trial Court". Do not code the name of the state. 

Thomas E. PEREZ, Secretary of Labor, et al., Petitioners
v.
MORTGAGE BANKERS ASSOCIATION et al.
Jerome Nickols, et al., Petitioners
v.
Mortgage Bankers Association.
Nos. 13-1041
13-1052.
Supreme Court of the United States
Argued Dec. 1, 2014.
Decided March 9, 2015.
Edwin S. Kneedler, Washington, DC, for Petitioners.
Allyson N. Ho, Dallas, TX, for Respondents.
Donald B. Verrilli, Jr., Solicitor General, Counsel of Record, Department of Justice, Washington, DC, for Petitioners.
Sam S. Shaulson, Morgan, Lewis & Bockius LLP, New York, NY, Michael W. Steinberg, Morgan, Lewis & Bockius LLP, Washington, DC, Allyson N. Ho, Counsel of Record, John C. Sullivan, Morgan, Lewis & Bockius LLP, Dallas, TX, for Respondent Mortgage Bankers Association.
M. Patricia Smith, Solicitor of Labor, Jennifer S. Brand, Associate Solicitor, Paul L. Frieden, Counsel for Appellate Litigation, Rachel Goldberg, Senior Attorney, U.S. Department of Labor, Washington, DC, Donald B. Verrilli, Jr., Solicitor General, Counsel of Record, Stuart F. Delery, Assistant Attorney General, Edwin S. Kneedler, Deputy Solicitor General, Anthony A. Yang, Assistant to the Solicitor General, Douglas N. Letter, Anthony J. Steinmeyer, Attorneys, Department of Justice, Washington, DC, for Federal Petitioners.
Adam W. Hansen, Counsel of Record, Nichols Kaster, LLP, San Francisco, CA, Paul J. Lukas, Rachhana T. Srey, Nichols Kaster, PLLP, Minneapolis, MN, Sundeep Hora, Alderman, Devorsetz & Hora PLLC, Washington, DC, for Petitioners.
Opinion
Justice SOTOMAYORdelivered the opinion of the Court.
When a federal administrative agency first issues a rule interpreting one of its regulations, it is generally not required to follow the notice-and-comment rulemaking procedures of the Administrative Procedure Act (APA or Act). See 5 U.S.C. § 553(b)(A). The United States Court of Appeals for the District of Columbia Circuit has nevertheless held, in a line of cases beginning with Paralyzed Veterans of Am. v. D.C. Arena L.P.,117 F.3d 579 (1997), that an agency must use the APA's notice-and-comment procedures when it wishes to issue a new interpretation of a regulation that deviates significantly from one the agency has previously adopted. The question in these cases is whether the rule announced in Paralyzed Veteransis consistent with the APA. We hold that it is not.
I
A
The APA establishes the procedures federal administrative agencies use for "rule making," defined as the process of "formulating, amending, or repealing a rule." § 551(5). "Rule," in turn, is defined broadly to include "statement [s] of general or particular applicability and future effect" that are designed to "implement, interpret, or prescribe law or policy." § 551(4).
Section 4 of the APA, 5 U.S.C. § 553, prescribes a three-step procedure for so-called "notice-and-comment rulemaking." First, the agency must issue a "[g]eneral notice of proposed rule making," ordinarily by publication in the Federal Register.§ 553(b). Second, if "notice [is] required," the agency must "give interested persons an opportunity to participate in the rule making through submission of written data, views, or arguments." § 553(c). An agency must consider and respond to significant comments received during the period for public comment. See Citizens to Preserve Overton Park, Inc. v. Volpe,401 U.S. 402, 416, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971); Thompson v. Clark,741 F.2d 401, 408 (C.A.D.C.1984). Third, when the agency promulgates the final rule, it must include in the rule's text "a concise general statement of [its] basis and purpose." § 553(c). Rules issued through the notice-and-comment process are often referred to as "legislative rules" because they have the "force and effect of law." Chrysler Corp. v. Brown,441 U.S. 281, 302-303, 99 S.Ct. 1705, 60 L.Ed.2d 208 (1979)(internal quotation marks omitted).
Not all "rules" must be issued through the notice-and-comment process. Section 4(b)(A) of the APA provides that, unless another statute states otherwise, the notice-and-comment requirement "does not apply" to "interpretative rules, general statements of policy, or rules of agency organization, procedure, or practice." 5 U.S.C. § 553(b)(A). The term "interpretative rule," or "interpretive rule,"is not further defined by the APA, and its precise meaning is the source of much scholarly and judicial debate. See generally Pierce, Distinguishing Legislative Rules From Interpretative Rules, 52 Admin. L.Rev. 547 (2000); Manning, Nonlegislative Rules, 72 Geo. Wash. L.Rev. 893 (2004). We need not, and do not, wade into that debate here. For our purposes, it suffices to say that the critical feature of interpretive rules is that they are "issued by an agency to advise the public of the agency's construction of the statutes and rules which it administers." Shalala v. Guernsey Memorial Hospital,514 U.S. 87, 99, 115 S.Ct. 1232, 131 L.Ed.2d 106 (1995)(internal quotation marks omitted). The absence of a notice-and-comment obligation makes the process of issuing interpretive rules comparatively easier for agencies than issuing legislative rules. But that convenience comes at a price: Interpretive rules "do not have the force and effect of law and are not accorded that weight in the adjudicatory process." Ibid.
B
These cases began as a dispute over efforts by the Department of Labor to determine whether mortgage-loan officers are covered by the Fair Labor Standards Act of 1938 (FLSA), 52 Stat. 1060, as amended, 29 U.S.C. § 201 et seq.The FLSA "establishe[s] a minimum wage and overtime compensation for each hour worked in excess of 40 hours in each workweek" for many employees. Integrity Staffing Solutions, Inc. v. Busk,574 U.S. ----, ----, 135 S.Ct. 513, 516, 190 L.Ed.2d 410 (2014). Certain classes of employees, however, are exempt from these provisions. Among these exempt individuals are those "employed in a bona fide executive, administrative, or professional capacity ... or in the capacity of outside salesman ...." § 213(a)(1). The exemption for such employees is known as the "administrative" exemption.
The FLSA grants the Secretary of Labor authority to "defin[e]" and "delimi[t]" the categories of exempt administrative employees. Ibid. The Secretary's current regulations regarding the administrative exemption were promulgated in 2004 through a notice-and-comment rulemaking. As relevant here, the 2004 regulations differed from the previous regulations in that they contained a new section providing several examples of exempt administrative employees. See 29 C.F.R. § 541.203. One of the examples is "[e]mployees in the financial services industry," who, depending on the nature of their day-to-day work, "generally meet the duties requirements for the administrative exception." § 541.203(b). The financial services example ends with a caveat, noting that "an employee whose primary duty is selling financial products does not qualify for the administrative exemption." Ibid.
In 1999 and again in 2001, the Department's Wage and Hour Division issued letters opining that mortgage-loan officers do not qualify for the administrative exemption. See Opinion Letter, Loan Officers/Exempt Status, 6A LRR, Wages and Hours Manual 99:8351 (Feb. 16, 2001); Opinion Letter, Mortgage Loan Officers/Exempt Status, id.,at 99:8249. (May 17, 1999). In other words, the Department concluded that the FLSA's minimum wage and maximum hour requirements applied to mortgage-loan officers. When the Department promulgated its current FLSA regulations in 2004, respondent Mortgage Bankers Association (MBA), a national trade association representing real estate finance companies, requested a new opinion interpreting the revised regulations. In 2006, the Department issued an opinion letter finding that mortgage-loan officers fell within the administrative exemption under the 2004 regulations. See App. to Pet. for Cert. in No. 13-1041, pp. 70a-84a. Four years later, however, the Wage and Hour Division again altered its interpretation of the FLSA's administrative exemption as it applied to mortgage-loan officers. Id.,at 49a-69a. Reviewing the provisions of the 2004 regulations and judicial decisions addressing the administrative exemption, the Department's 2010 Administrator's Interpretation concluded that mortgage-loan officers "have a primary duty of making sales for their employers, and, therefore, do not qualify" for the administrative exemption. Id.,at 49a, 69a. The Department accordingly withdrew its 2006 opinion letter, which it now viewed as relying on "misleading assumption[s] and selective and narrow analysis" of the exemption example in § 541.203(b). Id.,at 68a. Like the 1999, 2001, and 2006 opinion letters, the 2010 Administrator's Interpretation was issued without notice or an opportunity for comment.
C
MBA filed a complaint in Federal District Court challenging the Administrator's Interpretation. MBA contended that the document was inconsistent with the 2004 regulation it purported to interpret, and thus arbitrary and capricious in violation of § 10 of the APA, 5 U.S.C. § 706. More pertinent to this case, MBA also argued that the Administrator's Interpretation was procedurally invalid in light of the D.C. Circuit's decision in Paralyzed Veterans,117 F.3d 579. Under the Paralyzed Veteransdoctrine, if "an agency has given its regulation a definitive interpretation, and later significantly revises that interpretation, the agency has in effect amended its rule, something it may not accomplish" under the APA "without notice and comment." Alaska Professional Hunters Assn., Inc. v. FAA,177 F.3d 1030, 1034 (C.A.D.C.1999). Three former mortgage-loan officers-Beverly Buck, Ryan Henry, and Jerome Nickols-subsequently intervened in the case to defend the Administrator's Interpretation.
The District Court granted summary judgment to the Department. Mortgage Bankers Assn. v. Solis,864 F.Supp.2d 193 (D.D.C.2012). Though it accepted the parties' characterization of the Administrator's Interpretation as an interpretive rule, id.,at 203, n. 7, the District Court determined that the Paralyzed Veteransdoctrine was inapplicable because MBA had failed to establish its reliance on the contrary interpretation expressed in the Department's 2006 opinion letter. The Administrator's Interpretation, the District Court further determined, was fully supported by the text of the 2004 FLSA regulations. The court accordingly held that the 2010 interpretation was not arbitrary or capricious.
The D.C. Circuit reversed. Mortgage Bankers Assn. v. Harris,720 F.3d 966 (2013). Bound to the rule of Paralyzed Veteransby precedent, the Court of Appeals rejected the Government's call to abandon the doctrine. 720 F.3d, at 967, n. 1. In the court's view, "[t]he only question" properly before it was whether the District Court had erred in requiring MBA to prove that it relied on the Department's prior interpretation. Id.,at 967. Explaining that reliance was not a required element of the Paralyzed Veteransdoctrine, and noting the Department's concession that a prior, conflicting interpretation of the 2004 regulations existed, the D.C. Circuit concluded that the 2010 Administrator's Interpretation had to be vacated.
We granted certiorari, 573 U.S. ----, 134 S.Ct. 2820, 189 L.Ed.2d 784 (2014), and now reverse.
II
The Paralyzed Veteransdoctrine is contrary to the clear text of the APA's rulemaking provisions, and it improperly imposes on agencies an obligation beyond the "maximum procedural requirements" specified in the APA, Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc.,435 U.S. 519, 524, 98 S.Ct. 1197, 55 L.Ed.2d 460 (1978).
A
The text of the APA answers the question presented. Section 4 of the APA provides that "notice of proposed rule making shall be published in the Federal Register." 5 U.S.C. § 553(b). When such notice is required by the APA, "the agency shall give interested persons an opportunity to participate in the rule making." § 553(c). But § 4 further states that unless "notice or hearing is required by statute," the Act's notice-and-comment requirement "does not apply ... to interpretative rules." § 553(b)(A). This exemption of interpretive rules from the notice-and-comment process is categorical, and it is fatal to the rule announced in Paralyzed Veterans.
Rather than examining the exemption for interpretive rules contained in § 4(b)(A) of the APA, the D.C. Circuit in Paralyzed Veteransfocused its attention on § 1 of the Act. That section defines "rule making" to include not only the initial issuance of new rules, but also "repeal[s]" or "amend[ments]" of existing rules. See § 551(5). Because notice-and-comment requirements may apply even to these later agency actions, the court reasoned, "allow[ing] an agency to make a fundamental change in its interpretation of a substantive regulation without notice and comment" would undermine the APA's procedural framework. 117 F.3d, at 586.
This reading of the APA conflates the differing purposes of §§ 1 and 4 of the Act. Section 1 defines what a rulemaking is. It does not, however, say what procedures an agency must use when it engages in rulemaking. That is the purpose of § 4. And § 4 specifically exempts interpretive rules from the notice-and-comment requirements that apply to legislative rules. So, the D.C. Circuit correctly read § 1 of the APA to mandate that agencies use the same procedures when they amend or repeal a rule as they used to issue the rule in the first instance. See F.C.C. v. Fox Television Stations, Inc.,556 U.S. 502, 515, 129 S.Ct. 1800, 173 L.Ed.2d 738 (2009)(the APA "make[s] no distinction ... between initial agency action and subsequent agency action undoing or revising that action"). Where the court went wrong was in failing to apply that accurate understanding of § 1 to the exemption for interpretive rules contained in § 4: Because an agency is not required to use notice-and-comment procedures to issue an initial interpretive rule, it is also not required to use those procedures when it amends or repeals that interpretive rule.
B
The straightforward reading of the APA we now adopt harmonizes with longstanding principles of our administrative law jurisprudence. Time and again, we have reiterated that the APA "sets forth the full extent of judicial authority to review executive agency action for procedural correctness." Fox Television Stations, Inc.,556 U.S., at 513, 129 S.Ct. 1800. Beyond the APA's minimum requirements, courts lack authority "to impose upon [an] agency its own notion of which procedures are 'best' or most likely to further some vague, undefined public good." Vermont Yankee,435 U.S., at 549, 98 S.Ct. 1197. To do otherwise would violate "the very basic tenet of administrative law that agencies should be free to fashion their own rules of procedure." Id.,at 544, 98 S.Ct. 1197.
These foundational principles apply with equal force to the APA's procedures for rulemaking. We explained in Vermont Yankeethat § 4 of the Act "established the maximum procedural requirements which Congress was willing to have the courts impose upon agencies in conducting rulemaking procedures."Id.,at 524, 98 S.Ct. 1197. "Agencies are free to grant additional procedural rights in the exercise of their discretion, but reviewing courts are generally not free to impose them if the agencies have not chosen to grant them." Ibid.
The Paralyzed Veteransdoctrine creates just such a judge-made procedural right: the right to notice and an opportunity to comment when an agency changes its interpretation of one of the regulations it enforces. That requirement may be wise policy. Or it may not. Regardless, imposing such an obligation is the responsibility of Congress or the administrative agencies, not the courts. We trust that Congress weighed the costs and benefits of placing more rigorous procedural restrictions on the issuance of interpretive rules. See id.,at 523, 98 S.Ct. 1197(when Congress enacted the APA, it "settled long-continued and hard-fought contentions, and enact[ed] a formula upon which opposing social and political forces have come to rest" (internal quotation marks omitted)). In the end, Congress decided to adopt standards that permit agencies to promulgate freely such rules-whether or not they are consistent with earlier interpretations. That the D.C. Circuit would have struck the balance differently does not permit that court or this one to overturn Congress' contrary judgment. Cf. Law v. Siegel,571 U.S. ----, ----, 134 S.Ct. 1188, 1197-1198, 188 L.Ed.2d 146 (2014).
III
MBA offers several reasons why the Paralyzed Veteransdoctrine should be upheld. They are not persuasive.
A
MBA begins its defense of the Paralyzed Veteransdoctrine by attempting to bolster the D.C. Circuit's reading of the APA. "Paralyzed Veterans," MBA contends, "simply acknowledges the reality that where an agency significantly alters a prior, definitive interpretation of a regulation, it has effectively amended the regulation itself," something that under the APA requires use of notice-and-comment procedures. Brief for Respondent 20-21.
The act of "amending," however, in both ordinary parlance and legal usage, has its own meaning separate and apart from the act of "interpreting." Compare Black's Law Dictionary 98 (10th ed. 2014) (defining "amend" as "[t]o change the wording of" or "formally alter ... by striking out, inserting, or substituting words"), with id.,at 943 (defining "interpret" as "[t]o ascertain the meaning and significance of thoughts expressed in words"). One would not normally say that a court "amends" a statute when it interprets its text. So too can an agency "interpret" a regulation without "effectively amend[ing]" the underlying source of law. MBA does not explain how,precisely, an interpretive rule changes the regulation it interprets, and its assertion is impossible to reconcile with the longstanding recognition that interpretive rules do not have the force and effect of law. See Chrysler Corp.,441 U.S., at 302, n. 31, 99 S.Ct. 1705(citing Attorney General's Manual on the Administrative Procedure Act 30, n. 3 (1947)); Skidmore v. Swift & Co.,323 U.S. 134, 140, 65 S.Ct. 161, 89 L.Ed. 124 (1944).
MBA's "interpretation-as-amendment" theory is particularly odd in light of the limitations of the Paralyzed Veteransdoctrine. Recall that the rule of Paralyzed Veteransapplies only when an agency has previously adopted an interpretation of its regulation. Yet in that initial interpretation as much as all that come after, the agency is giving a definite meaning to an ambiguous text-the very act MBA insists requires notice and comment. MBA is unable to say why its arguments regarding revised interpretations should not also extend to the agency's first interpretation.
Next, MBA argues that the Paralyzed Veteransdoctrine is more consistent with this Court's "functional" approach to interpreting the APA. Relying on Christensen v. Harris County,529 U.S. 576, 120 S.Ct. 1655, 146 L.Ed.2d 621 (2000), and Shalala v. Guernsey Memorial Hospital,514 U.S. 87, 115 S.Ct. 1232, 131 L.Ed.2d 106, MBA contends that we have already recognized that an agency may not "avoid notice-and-comment procedures by cloaking its actions in the mantle of mere 'interpretation.' " Brief for Respondent 23-2

Question: What is the court whose decision the Supreme Court reviewed?
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Answer: