Learning Resources, Inc. v. Trump
The Court holds that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. Because tariffs are a branch of the taxing power that Article I of the Constitution assigns to Congress alone, the President must identify clear congressional authorization to impose them — and IEEPA's grant of authority to "regulate . . . importation," which never mentions tariffs or duties, does not supply it.
Opinion: https://www.supremecourt.gov/opinions/25pdf/24-1287_new_3135.pdf
Case background
Shortly after taking office, President Trump invoked the International Emergency Economic Powers Act (IEEPA) to address what he identified as two foreign threats: the influx of illegal drugs from Canada, Mexico, and China, and “large and persistent” trade deficits. Declaring a national emergency as to each and deeming the threats “unusual and extraordinary,” the President imposed two sets of tariffs — “drug trafficking” tariffs of 25% on most Canadian and Mexican imports and 10% on most Chinese imports, and “reciprocal” tariffs of at least 10% on imports from all trading partners, with dozens of nations facing higher rates. He then issued numerous further increases, reductions, and modifications.
Two groups of plaintiffs sued, alleging that IEEPA does not authorize either set of tariffs. The Learning Resources plaintiffs — two small businesses — sued in the U.S. District Court for the District of Columbia, which denied the Government’s motion to transfer the case to the Court of International Trade (CIT) and preliminarily enjoined the tariffs. The V.O.S. Selections plaintiffs — five small businesses and 12 States — sued in the CIT, which granted them summary judgment. The Federal Circuit, sitting en banc, affirmed in relevant part, holding that IEEPA’s grant of authority to “regulate . . . importation” did not authorize the challenged tariffs, which “are unbounded in scope, amount, and duration.” The Court granted certiorari — including before judgment in Learning Resources — and consolidated the cases.
Questions Presented
- Whether IEEPA authorizes the President to impose tariffs.
Holding
IEEPA does not authorize the President to impose tariffs. Article I, Section 8 of the Constitution gives Congress alone the power to “lay and collect Taxes, Duties, Imposts and Excises,” and the power to impose tariffs is a branch of that taxing power; the Government concedes the President has no inherent peacetime authority to impose them. The President must therefore point to clear congressional authorization, and IEEPA’s authority to “regulate . . . importation” does not supply it: the statute never mentions tariffs or duties, the ordinary power to “regulate” does not include the distinct power to tax, and no President had invoked IEEPA to impose tariffs in the statute’s nearly half-century of existence. The judgment in No. 24-1287 is vacated and remanded with instructions to dismiss for lack of jurisdiction, and the judgment in No. 25-250 is affirmed.
The Court
Chief Justice Roberts announced the judgment of the Court and delivered the opinion of the Court, except as to Parts II–A–2 and III, which were joined only by Justice Gorsuch and Justice Barrett. The Court divided 6–3 on the result. Justice Gorsuch filed a concurring opinion, and Justice Barrett filed a concurring opinion. Justice Kagan filed an opinion concurring in part and concurring in the judgment, joined by Justice Sotomayor and Justice Jackson, agreeing that IEEPA does not authorize the tariffs but concluding that ordinary tools of statutory interpretation — rather than the major questions doctrine — sufficed to decide the case. Justice Jackson also filed a separate opinion concurring in part and concurring in the judgment, adding that she would consult legislative history. Justice Kavanaugh filed a dissenting opinion, joined by Justice Thomas and Justice Alito. Justice Thomas filed a separate dissenting opinion.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in *Learning Resources, Inc. v. Trump *, written by Justice Roberts.
AI disclosure: The voice in this episode is AI-generated, using a machine learning model styled to loosely resemble the authoring justice. Tone, inflection, pacing, and emphasis are artifacts of the model and should not be attributed to Justice Roberts. The text being read is the Court’s published majority opinion, lightly adapted to improve readability for the spoken format.