Executive Summary
In Learning Resources, Inc. v. Trump (Nos. 24–1287 and 25–250, decided February 20, 2026), the Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. President Trump had declared national emergencies under IEEPA to address drug trafficking from Canada, Mexico, and China, as well as persistent trade deficits, imposing broad tariffs (e.g., 25% on most Canadian/Mexican imports, 10% on Chinese imports for drugs; at least 10% on all imports for deficits, with modifications). Challengers—small businesses and states—successfully argued that IEEPA's grant of power to "regulate... importation" does not include the taxing power of tariffs, which is constitutionally vested in Congress. The Court vacated one lower court judgment for lack of jurisdiction and affirmed the other, emphasizing separation of powers, statutory text, and the major questions doctrine. Chief Justice Roberts wrote the majority opinion, with concurrences from Justices Kagan (joined by Sotomayor and Jackson) and Jackson, and dissents from Justices Thomas and Kavanaugh (joined by Thomas and Alito).
Longer Summary
This 170-page Supreme Court opinion consolidates two cases challenging President Trump's use of the International Emergency Economic Powers Act (IEEPA), enacted in 1977 (91 Stat. 1626; 50 U.S.C. §1701 et seq.), to impose widespread tariffs. The document includes the syllabus (pp. 1–6), the majority opinion by Chief Justice Roberts (with partial joins), concurring opinions, and dissenting opinions. Below is a detailed breakdown based on the full content.
Background and Facts
Shortly after taking office in 2025, President Trump identified two "unusual and extraordinary" foreign threats under IEEPA: (1) the influx of illegal drugs from Canada, Mexico, and China, which he deemed a public health crisis (Presidential Proclamation No. 10886, 90 Fed. Reg. 8327; Exec. Orders Nos. 14193–14195, 90 Fed. Reg. 9113–9123); and (2) "large and persistent" trade deficits, which he said hollowed out American manufacturing and undermined supply chains (Exec. Order No. 14257, 90 Fed. Reg. 15041).
To address these, he declared national emergencies and invoked IEEPA's authority to "deal with" such threats by regulating importation/exportation of property with foreign interests (§1702(a)(1)(B)). Specific actions included:
- Drug Trafficking Tariffs: 25% duty on most Canadian and Mexican imports; 10% on most Chinese imports (with subsequent increases, reductions, and modifications).
- Reciprocal (Trade Deficit) Tariffs: At least 10% duty on all imports from all trading partners, with higher rates (up to dozens of nations facing more); later adjusted multiple times.
No prior President had used IEEPA for tariffs of this scope, amount, or duration.
Procedural History
The cases were consolidated for review:
- No. 24–1287 (Learning Resources, Inc. et al. v. Trump): Two small businesses sued in the U.S. District Court for the District of Columbia, alleging IEEPA does not authorize tariffs. The court denied the government's motion to transfer to the U.S. Court of International Trade (CIT) and granted a preliminary injunction, finding no such authority under IEEPA (784 F. Supp. 3d 209). Petitioners sought certiorari before judgment.
- No. 25–250 (Trump v. V.O.S. Selections, Inc. et al.): Five small businesses and 12 states sued in the CIT, which granted summary judgment for plaintiffs. The Federal Circuit, en banc, affirmed in relevant part (149 F. 4th 1312), holding that IEEPA's "regulate... importation" does not authorize "unbounded" tariffs.
The Supreme Court granted certiorari in both (argued November 5, 2025) to resolve whether IEEPA authorizes presidential tariffs.
Holding and Majority Opinion (Chief Justice Roberts)
The Court held that IEEPA does not authorize the President to impose tariffs, vacating the judgment in No. 24–1287 (and remanding with instructions to dismiss for lack of jurisdiction) and affirming in No. 25–250.
- Part I (Unanimous): Outlines the facts, IEEPA's text, and procedural history.
- Part II–A–1 (Joined by Sotomayor, Kagan, Gorsuch, Barrett, Jackson): Emphasizes Congress's exclusive constitutional power under Article I, §8 to impose taxes, duties, and tariffs (citing Gibbons v. Ogden, 9 Wheat. 1, 201; The Federalist No. 48). The government conceded no inherent presidential peacetime tariff authority, relying solely on IEEPA's "regulate... importation." The Court rejected this as a "sweeping delegation" of Congress's core taxing power.
- Part II–A–2 (Joined by Gorsuch and Barrett): Applies the major questions doctrine (West Virginia v. EPA, 597 U.S. 697; Biden v. Nebraska, 600 U.S. 477), requiring "clear congressional authorization" for extraordinary powers. Tariffs here are economically and politically significant (dwarfing prior cases), with no historical precedent under IEEPA. Congress delegates tariff powers explicitly and with limits elsewhere, not vaguely. No exceptions for emergencies or foreign affairs apply, as the Framers vested tariffs solely in Congress peacetime (Merritt v. Welsh, 104 U.S. 694).
- Part II–B (Joined by Sotomayor, Kagan, Gorsuch, Barrett, Jackson): Statutory interpretation: IEEPA lists powers like "investigate, block, regulate, direct and compel" but omits "tariffs" or "duties." "Regulate" means to control or adjust, not tax (Black's Law Dictionary; no statute equates regulation with taxation). Neighboring verbs confirm sanctions-like actions, not revenue-raising. A contrary reading would violate the Export Tax Clause (Art. I, §9, cl. 5). Rejects arguments from Commerce Clause history, IEEPA's predecessor (Trading with the Enemy Act), wartime precedents, and cases like FEA v. Algonquin SNG (426 U.S. 548) and Dames & Moore v. Regan (453 U.S. 654).
- Part III (Joined by Gorsuch and Barrett): Addresses jurisdiction and remand.
Concurring Opinions
- Justice Kagan (joined by Sotomayor and Jackson): Agrees IEEPA lacks tariff authority but via ordinary statutory tools (text, context, history) alone, without major questions doctrine (pp. 1–7). Tariffs are taxes, not mere regulation; IEEPA's spectrum of powers (compel to prohibit) excludes revenue-raising.
- Justice Jackson: Agrees with Kagan but adds legislative history from House/Senate Reports on IEEPA and TWEA, showing Congress intended sanctions, not tariffs (pp. 1–5).
- Justice Gorsuch (concurring): Emphasizes separation of powers and reluctance to infer ambiguous delegations.
- Justice Barrett (concurring): Focuses on the "practical understanding of legislative intent" in major questions cases.
Dissenting Opinions
- Justice Thomas: Argues IEEPA's "regulate" includes tariffs as a form of commerce regulation, drawing from historical Commerce Clause views and wartime precedents.
- Justice Kavanaugh (joined by Thomas and Alito): IEEPA authorizes tariffs as a means to "regulate importation" (citing Yoshida Int'l, Inc., 526 F.2d 560; Algonquin). Rejects major questions doctrine here; views tariffs as within presidential foreign affairs discretion. Historical chain from TWEA supports this; no constitutional issue as tariffs regulate, not just tax.
The opinion reinforces Congress's primacy over tariffs, limiting executive emergency powers to statutory bounds. The full document Learning Resources, Inc. v. Trump (Nos. 24–1287 and 25–250,) includes citations, footnotes, and appendices on tariff impacts. Download the 107-page PDF [LINK]
If your device cannot download or process a PDF, a readable copy has been embedded below.
Learning Resources, Inc. v. Trump (Nos. 24–1287 and 25–250)
What Others Are Saying
Trump's Global Tariffs Struck Down by Supreme Court | Bloomberg Television https://youtu.be/o_NfkVMPjr0 NBC: Supreme Court strikes down most of Trump's tariffs in a major blow to the president https://www.nbcnews.com/politics/supreme-court/supreme-court-strikes-trumps-tariffs-major-blow-president-rcna244827 AP News: Supreme Court strikes down Trump’s sweeping tariffs, upending central plank of economic agenda https://apnews.com/article/supreme-court-tariffs-trump-0485fcda30a7310501123e4931dba3f9 Fox News: Supreme Court blocks Trump tariffs in major test of executive branch powers https://www.foxnews.com/politics/supreme-court-decision-donald-trump-tariff-powers New York Times Liveblog: Supreme Court Strikes Down Trump’s Sweeping Tariffs https://www.nytimes.com/live/2026/02/20/us/trump-tariffs-supreme-court?unlocked_article_code=1.NlA.VbQJ._4IMgASnl5rB
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Published at 11.00am on Friday, February 20, 2025
Author: Bobby Coggins
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