The Supreme Court's Decision: Learning Resources, Inc. v. Trump

On February 20, 2026, the Supreme Court issued its landmark ruling in Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026), holding 6-3 that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. The decision resolved consolidated cases from both the U.S. Court of International Trade and the U.S. District Court for the District of Columbia, settling one of the most significant trade law disputes in modern American history.

The Core Holding

The Court held that IEEPA's authority for the President to "regulate . . . importation" does not encompass the power to impose tariffs or duties. The majority opinion emphasized that IEEPA contains no reference to "tariffs" or "duties," and that Congress has historically delegated tariff authority expressly, with specific caps, duration limits, and procedural conditions, whenever it intended to grant such power. The Court characterized the claimed authority — unlimited tariffs on any product, any country, for any duration — as a "transformative expansion" of presidential power lacking clear congressional authorization.

Jurisdiction: The Court of International Trade

The Supreme Court confirmed that jurisdiction over IEEPA tariff challenges lies exclusively in the U.S. Court of International Trade (CIT) under 28 U.S.C. § 1581(i), because such challenges "arise out of" modifications to the Harmonized Tariff Schedule of the United States (HTSUS) made under an Act affecting import treatment. As a result, the D.C. District Court in Learning Resources lacked jurisdiction; the Court vacated that judgment and remanded with instructions to dismiss for lack of jurisdiction, while affirming the Federal Circuit in V.O.S. Selections and the CIT's jurisdictional analysis.

The Major Questions Doctrine

The Court applied the major questions doctrine, holding that a claim of authority with vast political and economic significance requires a clear statement from Congress. The government's claimed power — to impose unlimited tariffs on all products, from all countries, for any duration — was precisely the kind of unprecedented assertion requiring explicit authorization. The majority rejected any emergency exception to this doctrine, holding that urgency does not relax the clarity requirement. The Court also rejected the argument that the involvement of foreign affairs or national security warranted a more lenient standard.

Refunds and Remedies

The Supreme Court's opinion does not prescribe any specific refund mechanism or remedial procedure. The operative disposition invalidates the IEEPA-based tariffs and confirms that the CIT has authority to order reliquidation and refunds under its existing statutory powers. Implementation of any duty refund processing or reliquidation is left to the lower courts and CBP. Importers seeking refunds must file timely protests under 19 U.S.C. § 1514 with CBP and may challenge liquidation decisions in the CIT under 28 U.S.C. § 1581.

Limits of the Ruling

The Court carefully limited its holding to IEEPA specifically. It did not define the full scope of "regulate importation" for other IEEPA actions such as asset freezes, transaction prohibitions, or other sanctions-type measures. The opinion also expressly reserved the question of whether specific IEEPA tariffs might have been justified under other trade statutes. The decision did not reach the nondelegation doctrine argument, having resolved the case on statutory interpretation grounds.

Other Bases for Presidential Tariff Authority

The Court acknowledged that Congress has granted tariff authority elsewhere in the trade code — including Section 232 of the Trade Expansion Act, safeguard provisions (19 U.S.C. § 2253), and retaliation provisions (19 U.S.C. §§ 1338, 2411). Unlike IEEPA, these statutes contain explicit "duty" language, numerical caps, temporal limits, and procedural preconditions. The Court declined to opine on whether any specific IEEPA tariff could have been imposed under these alternative authorities, characterizing that question as hypothetical and outside the scope of the cases before it. All parties agreed that there is no inherent Article II peacetime tariff power; any such authority must be grounded in an authorizing statute.