Godinez-Arroyo v. Mukasey, 540 F.3d 848, 2008 WL 3927229 (8th Cir. Aug. 28, 2008) ("Even if Chevron deference is inappropriate, however, the BIA opinion would nevertheless be eligible for a lesser form of deference under Skidmore v. Swift & Co., 323 U.S. 134, 65 S.Ct. 161, 89 L.Ed. 124 (1944). See Mead Corp., 533 U.S. at 234, 121 S.Ct. 2164 (noting that "Chevron did nothing to eliminate Skidmore's holding that an agency's interpretation may merit some deference whatever its form, given the specialized experience and broader investigations and information available to the agency ... and given the value of uniformity in its administrative and judicial understandings of what a national law requires" (internal citations and quotation omitted)). Under Skidmore deference, "the ruling is eligible to claim respect according to its persuasiveness," Mead Corp., 533 U.S. at 221, 121 S.Ct. 2164, but is "worth no more than its inherent persuasive value," Kai v. Ross, 336 F.3d 650, 655 (8th Cir.2003). The opinion is afforded weight "depend[ing] 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." Skidmore, 323 U.S. at 140, 65 S.Ct. 161; Kai, 336 F.3d at 655.").