Consumer Product Safety Comm'n v. GTE Sylvania

In Consumer Product Safety Comm'n v. GTE Sylvania, 447 U.S. 102, 100 S.Ct. 2051, 64 L.Ed.2d 766 (1980)., the Supreme Court refused to give substantial weight to remarks made at a subsequent hearing and in a subsequent committee report about what Congress intended by an earlier enactment. Id. at 118, 100 S.Ct. at 2061. The Court specifically distinguished subsequent legislation declaring the intent of an earlier statute, acknowledging that in the case of clarifying legislation "Congress has proceeded formally through the legislative process" the therefore the subsequent legislation may be entitled to great weight. Id. at 118 n. 13, 100 S.Ct. at 2061 n. 13 (citing Red Lion Broadcasting Co. v. FCC, 395 U.S. at 380-81, 89 S.Ct. at 1801-02).