Summary
The Supreme Court held that the International Emergency Economic Powers Act does not authorize the President to impose tariffs. The Court vacated and remanded the judgment in Learning Resources, Inc. v. Trump for lack of jurisdiction and affirmed the Federal Circuit's judgment in V.O.S. Selections. The decision addresses congressional taxing power, the major questions doctrine, and the meaning of IEEPA's authority to regulate importation.
Topics
Practice areas
Questions Presented
- Whether IEEPA authorizes the President to impose tariffs.
- Whether the Court of International Trade had exclusive jurisdiction over the V.O.S. Selections claims.
- Whether the District Court for the District of Columbia lacked jurisdiction because the Learning Resources claims arose out of laws providing for tariffs.
Holdings
- IEEPA does not authorize the President to impose tariffs. The statutory authority to regulate importation does not include the distinct power to impose tariffs or duties.
- The District Court for the District of Columbia lacked jurisdiction because the action arose out of laws providing for tariffs and therefore fell within the exclusive jurisdiction of the Court of International Trade.
- The judgment of the Federal Circuit affirming the Court of International Trade's judgment for the V.O.S. plaintiffs was affirmed.
Key quotations
“IEEPA does not authorize the President to impose tariffs.” (607 U.S. at 230)
“Accordingly, the President must "point to clear congressional authorization" to justify his extraordinary assertion of the power to impose tariffs. Nebraska, 600 U.S., at 506 (internal quotation marks omitted). He cannot.” (607 U.S. at 248)
“IEEPA's grant of authority to "regulate importation" falls short. IEEPA contains no reference to tariffs or duties.” (607 U.S. at 255)
Factual background
President Trump declared national emergencies concerning illegal-drug inflows from Canada, Mexico, and China and persistent trade deficits. Invoking the International Emergency Economic Powers Act, he imposed tariffs ranging from 10 percent to 145 percent on imports from numerous countries and later modified those tariffs. Small businesses and twelve States challenged the tariffs, arguing that IEEPA does not authorize the President to impose them.
Procedural history
Learning Resources plaintiffs sued in the District Court for the District of Columbia, which denied transfer to the Court of International Trade and granted a preliminary injunction after concluding that IEEPA did not authorize the tariffs. V.O.S. Selections plaintiffs sued in the Court of International Trade, which granted summary judgment; the Federal Circuit, sitting en banc, affirmed in relevant part. The Supreme Court granted both petitions and consolidated the cases.
Remand instructions
In No. 24-1287, the judgment of the District Court for the District of Columbia was vacated and the case was remanded with instructions to dismiss for lack of jurisdiction. In No. 25-250, the Federal Circuit judgment was affirmed.