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Note: Where feasible, the judgment summary (comments) will be published simultaneously with the judgment opinion of this case. This summary of judgment does not constitute part of the court's judgment opinion but was prepared by the judgment reporter for the convenience of readers. See United States v. Detroit Lumber Company, 200 U.S. 321, 337.
U.S. Supreme Court
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Learning Resources Company and others v. President Trump and others
Application for a summons order from the Court of Appeals for the District of Columbia Circuit
Case number 24-1287. Debate date: November 5, 2025 — Decision date: February 20, 2026
The focus of the dispute in this case is whether the International Emergency Economic Powers Act (IEEPA) authorizes the President to impose tariffs. See Compendium of Federal Regulations, Vol. 91, p. 1626. Shortly after taking office, President Trump began addressing two major external threats: first, the influx of illegal drugs from Canada, Mexico, and CHINA (Presidential Proclamation No. 10886, 90 Federal Register, p. 8327); Executive Order No. 14193, page 90 of the Federal Register; Executive Order No. 14194, 90 Federal Register, p. 9117; Executive Order No. 14195, 90 Federal Register, p. 9121); The second is the "persistent and severe" trade deficit (Executive Order No. 14257, 90 Federal Register p. 15041). The President determined that the influx of illegal drugs had "triggered a public health crisis" (Federal Register 90). According to Executive Order 9113, the trade deficit has "hollowed out the foundation of U.S. manufacturing" and "disrupted critical supply chains" (ibid., p. 15041). The President declared a national emergency in response to these two threats, deeming them "unusual and special," and exercising response powers under the International Emergency Economic Powers Act (IEEPA).
He imposed tariffs on each threat: for drug smuggling, the President imposed a 25% tariff on most Canadian and Mexican imports, and a 10% tariff on CHINA imports (ibid., pp. 9114, 9118, 9122-9123); Regarding trade deficit ("reciprocity") tariffs, the president imposes tariffs of at least 10% on imports from all trading partners, with dozens of countries facing higher rates. Ibid., pp. 15045, 15049. Since the implementation of each set of tariffs, the President has adjusted the rates multiple times, including raises, reductions, and other modifications.
In the "Learning Resources case" plaintiff and "V.O.S. Select" case, the defendants filed lawsuits accusing IEEPA of failing to authorize reciprocity tariffs or drug smuggling duties. The plaintiffs in the "Learning Resources case"—two small businesses—filed a lawsuit in the U.S. District Court for the District of Columbia. The court denied the government's motion to refer the case to the U.S. Court of International Trade (CIT) and granted the plaintiffs' preliminary injunction motion, finding that IEEPA did not grant the President the authority to impose tariffs. The plaintiffs in the "V.O.S. Selection"—five small businesses and twelve states—filed lawsuits against CIT. The court issued a summary judgment in favor of the plaintiff. After hearing the case, the full bench of judges of the Federal Circuit upheld the original judgment on relevant matters, holding that IEEPA grants the President "regulation...... The power to "import" does not authorize the imposition of the questioned tariffs, which "have no limits on scope, amount, or duration." 149 F.4th 1312,1338。 The government submitted an application for an order to recover the "V.O.S. Selected Case," while the plaintiffs in the "Learning Resources Case" submitted an application for an order before the judgment. The court approved these applications and consolidated the cases for trial.
Final ruling: IEEPA did not authorize the president to impose tariffs. Judgment No. 24-1287 was overturned, and the case was remanded for retrial, with instructions to dismiss due to lack of jurisdiction; Uphold judgment No. 25-250.
Judgment No. 24-1287 (784 F. Supp. 3d 209) was overturned and remanded for retrial; Judgment No. 25-250 (149 F. 4th 1312) was upheld.
The Chief Justice issued the Court's opinion on Section A-A1 of Part One and Part Two:
Article 1, Paragraph 8 of the Constitution clearly states, "Congress has the power to formulate and levy taxes, tariffs, excise taxes, and excise taxes." The framers recognized the unique importance of this taxing power—the power "very explicitly" included the authority to collect tariffs (Gibbons v. Ogden, 9 Wheat. 1,201）。 They gave Congress the "only..." "Access to the pockets of the people" (Federalist Papers, p. 48, p. 310, J. Madison). The framers did not grant any taxation authority to the executive branch (see Nicole v. Ames, 173 U.S. 509, 515). Therefore, the government acknowledges that the president does not have the inherent authority to impose tariffs during peacetime and instead relies entirely on IEEPA to defend the questioned tariff policy. This provision interprets the terms "regulation" and "import" as broad authorization of Congress's tariff policy-making power—authorizing the President to impose tariffs on any product from any country with no cap on amount or no time limit. See Title 50 of the Code of Federal Regulations, Section 1702(a)(1)(B), pp. 5–7.
The Chief Justice, Justice Gorsuch, and Justice Barrett reached a consensus in Part Two, Chapters A-2:
The Supreme Court has long maintained the position of "unwilling to interpret" Congress in vaguely defined statutory texts to delegate unconventional powers to executive branches. Virginia v. EPA, 597 U.S. 697,723 (cited in Utility Air Regulatory Group v. EPA, 573 U.S. 302, 324). In multiple cases involving "major issues," this court holds that the "principle of separation of powers and a pragmatic understanding of legislative intent" indicate that Congress will not grant "powers of significant influence" through vague wording (ibid., pp. 723-724). These considerations are especially important when it comes to Congress's core fiscal powers. Congressional practice fully demonstrates this: when granting tariff rights, Congress always imposes clear provisions and strict limits.
Based on this clear and limited authorization background, the government interprets IEEPA as granting the president the authority to unilaterally impose tariffs indefinitely and adjust them at will. This interpretation would lead to a fundamental expansion of the president's authority over tariff policy. It is worth noting that in the half-century since IEEPA's enactment, no president has ever invoked the law to implement any tariffs, let alone tariffs of such scale and scope. The president's current claim of "lack of historical precedent" combined with "broad legislative authority" indicates that these tariffs exceed the president's "legitimate authority." National Federation of Independent Enterprises v. Occupational Safety and Health Administration, 595 U.S. 109, 119 (cited from Free Enterprise Fund v. Listed Company Accounting Supervisory Board 561 U.S. 477, 505). The "economic and political importance" advocated by the President also "constitutes reasons to be carefully considered before determining that Congress intends to grant this power." West Virginia Case, 597 U.S., p. 721 (cited in FDA v. Brown-Williamson Tobacco Company 529 U.S. 120, 159-160). The significance of the interests involved in this case pales in comparison to other major issues and cases. As those cases show, "reasonable interpreters would not expect Congress to hand over such a major policy decision" to "another branch." BIDEN v. Nebraska, 600 U.S. 477, 515 (second opinion of Justice Barrett).
The principle of major issues does not make exceptions to the fact that the relevant decree is an emergency decree. The fact that tariffs involve foreign affairs does not mean the principle is inapplicable. The framers only granted the power to levy tariffs during peacetime to "Congress itself." See Merritt v. Welch, 104 U.S. 694, 700. The diplomatic nature of tariffs does not increase the likelihood that Congress will delegate its tariff powers through vague wording or without strict restrictions. Therefore, the President must "point out clear congressional authorization" to justify his unconventional claims to this power. See Nebraska case, 600 U.S., p. 506 (internal quotation marks omitted). The president failed to do so. pp. 7–13.
The Chief Justice elaborated on the court's opinion on Part Two, Section B, and ultimately concluded:
(a) Section 1702(a)(1)(B) of the United States Code of Federal Statutes authorizes the President to "investigate, enforce, regulate, guide, enforce, repeal, nullify, prevent, or prohibit during the investigation...... Import and export. This detailed list of powers does not mention tariffs or tariff rules. If Congress intended to grant the special and extraordinary power to impose tariffs, it should have been stated as clearly as in other tariff regulations.
"Regulation...... The power to "import" has not filled this gap. According to page 1156 of the Black Dictionary of Law, the term "regulation" usually means "fixed, established, or controlled; Adjustments are made through rules, methods, or established patterns; Guidance through rules or restrictions; Subject to governance principles or laws." The literal breadth of this definition sharply highlights what "regulation" usually does not include: taxation. Many regulations grant the executive branch the power to "regulate," but the government has failed to find any legislation that incorporates taxation authority into regulatory power. Therefore, the court questioned IEEPA—and only IEEPA—that Congress had implicitly embedded its rightful taxation power within its daily "regulatory" powers.
Although taxation may serve regulatory purposes, this does not mean that regulatory powers include the power to use taxation as a means of regulation. In fact, when Congress discusses regulatory powers and taxing powers simultaneously, its wording is clear and separate. This distinction was not made in this case, fully demonstrating that the term "regulation" in the IEEPA case does not include taxation rights.
If interpreted in the opposite way, it would make IEEPA partially unconstitutional. According to Section 1702(a)(1)(B), the President has the authority to "regulate..." Import and export trade." However, the Constitution explicitly prohibits the imposition of export taxes (Article 1, Paragraph 9, Item 5 of the Constitution).
The "neighboring words" associated with the word "regulation" also indicate that Congress does not intend to include taxing power within the scope of "regulation." United States v. Williams, 553 U.S. 285, 294. All nine verbs in Section 1702(a)(1)(B) authorize the President to impose sanctions on foreign actors or control domestic actors engaged in foreign trade, as evidenced by presidential practice. None of the listed legal grounds include this unique and special revenue-generating right—a power never asserted by any president in the IEEPA case. Pages 14-16.
(b) The multiple arguments listed to refute the above views are all unconvincing. First, some argue that the International Emergency Economic Powers Act grants the authority to impose tariffs, arguing that early commentators and this court case law had discussed tariff issues under commercial provisions, but this claim is irrelevant. The focus of the dispute in this case is not whether tariffs can serve as a means to regulate commerce, but rather Congress's decision to grant the President "regulation...... The authority to "import" is not granted to unilaterally impose tariffs. Congressional legislative practice is very clear: when granting the authority to collect tariffs, Congress always defines it with clear and prudent restrictions. Congress did not address both points in the International Emergency Economic Powers Act.
Second, the argument that the so-called "regulation" naturally includes tariffs does not hold up—the term lies at two extremes within IEEPA: one end is "mandatory," the other is "prohibition." Although tariffs may be milder than direct enforcement or bans, this does not mean tariffs fall somewhere in between the two ends; It is fundamentally different in nature from other regulatory measures in IEEPA, rather than in degree. Tariffs directly affect domestic importers to increase treasury revenues and "very clearly belong to the branch of taxation authority." Gibbons case, 9 Wheat., p. 201. Therefore, tariffs do not fall under this category at all.
Third, arguments based on the predecessor of IEEPA, the Anti-Adversarial Trade Act (TWEA), and the Customs and Patent Court of Appeals in the United States v. Yoshida International Company case (526 F.2d 560), are fundamentally unworthy of scrutiny. Ajudgment made by the specialized intermediate appellate court, which clearly states its limitations, is not sufficient to establish a legal meaning that has been established beyond doubt that this court may presume that Congress has incorporated it into the International Emergency Economic Powers Act.
Fourth, the historical argument based on wartime precedents from this court is also untenable. These precedents clearly do not apply, as everyone agrees that the President lacks the authority to collect tariffs in peacetime. And the indirect reasoning chain from wartime precedents to multiple TWEAs and IEEPA cannot support—let alone explicitly—an IEEPA interpretation that includes unique tariff collection rights.
Finally, the arguments relying on this court's precedents lack sufficient basis. The Federal Energy Administration v. Algonquin SNG (426 U.S. 548) has limited interpretive significance for IEEPA. Section 232(b) of the Trade Extension Act of 1962 contains broad discretionary provisions not covered by IEEPA, and the explicit provision of tariffs in section 232(a) naturally gives it the authority to impose tariffs. Daimes v. Moore v. Reagan (453 U.S. 654) is also unsupportive because its scope is extremely narrow, it does not involve presidential "regulatory" powers, and does not address tariff issues at all.
Justice Kagan, Sotomayor, and Justice Jackson reached a consensus on pages 16-20 that IEEPA does not authorize the President to levy tariffs, but believes the Court does not need to invoke the principle of material issues, as conventional legal interpretation is sufficient to support this conclusion. Pages 1–7.
Justice Jackson also advocated referencing legislative history—especially House and Senate reports alongside the International Emergency Economic Powers Act and its predecessor, the Trade Against the Enemy Act—to determine that Congress had no intention of authorizing the executive branch to impose tariffs under the Act. Pages 1–5.
Chief Justice Roberts announced the court's decision and issued court opinions on Sections I, II, A-1, and B, joined by Justices Sotomayor, Kagan, Gorsuch, Barrett, and Jackson; Court opinions were issued on Part II, Part A-2, and Part III, joined by Justices Gorsuch and Barrett. Justices Gorsuch and Barrett submitted a concurring opinion. Justice Kagan submitted partial concurring opinions and judgment concurring opinions, which were joined by Justices Sotomayor and Jackson. Justice Jackson submitted partial concurring opinions and judgment concurring opinions. Justice Thomas submitted an objection. Justice Kavanaugh filed an objection, and Justices Thomas and Alito joined the objection.
Note: See also Document 25-250: President Trump et al. v. V.O.S. Select et al., regarding the Federal Circuit's Court of Appeals for a remand order.
Note: The summary of the judgment in this case is mainly translated using software such as DEEPSEEK and Doubao; the Chinese translation is for reference only.