Is the Secretary of State's interpretation of the Civil Code of Civil Procedure deference?

The Secretary argues that his interpretation is entitled to deference under Skidmore v. Swift & Co. , 323 U.S. 134, 65 S.Ct. 161, 89 L.Ed. 124 (1944). Under Skidmore , the weight to be accorded the Secretary's interpretation "depend[s] upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control." Id. at 140, 65 S.Ct. 161. We have given careful consideration to each of these factors, but none of them persuades us that the Secretary's reading of the statute is the better one. We address below the main points the Secretary raises in arguing for Skidmore deference.