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U.S. Supreme Court Overturns Tariffs in Learning Resources, Inc. v. Trump

Supreme Court Overturns Tariffs in Learning Resources, Inc. v. Trump

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    This page is updated as developments occur following the U.S. Supreme Court’s decision overturning tariffs imposed under the International Emergency Economic Powers Act.

    March 6, 2026

    U.S. Court of International Trade Addresses IEEPA Tariff Refunds Following Supreme Court Ruling

    On March 4, 2026, the U.S. Court of International Trade (CIT) issued an order in Atmus Filtration, Inc. v. United States addressing refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), following the U.S. Supreme Court’s decision in Learning Resources, Inc. v. Trump.

    In its order, the CIT directed U.S. Customs and Border Protection (CBP) to:

    • Liquidate any unliquidated entries subject to IEEPA duties without those duties, and
    • Reliquidate entries that are not yet final without the IEEPA tariffs.

    The court’s language suggests that all importers of record whose entries were subject to IEEPA duties are entitled to the benefit of the Supreme Court’s decision, not only the named plaintiffs. However, the order provides limited guidance on how CBP will operationalize refunds across the millions of affected entries and leaves several procedural questions unresolved.

    What the CIT’s Order Means for Businesses

    The CIT’s order represents a significant development in the evolving IEEPA refund landscape. First, it signals the possibility of a coordinated or universal refund process, rather than relief limited only to litigants. That said, the order does not address:

    • Entries that have already liquidated and become final;
    • The specific administrative mechanics CBP will use to implement refunds;
    • The timeline for processing potentially millions of affected entries.

    Second, the ruling may face immediate appellate scrutiny. The Administration has publicly indicated that it intends to defend or object to tariff refunds aggressively. If appealed, the case would proceed to the U.S. Court of Appeals for the Federal Circuit and could ultimately return to the Supreme Court.

    How to Prepare for Potential IEEPA Tariff Refunds

    Although the CIT order signals meaningful progress toward refunds, the procedural framework continues to evolve. Companies affected by IEEPA tariffs should take proactive steps now to understand their potential exposure and position themselves for future developments.

    • Review Entry Status: Determine which import entries remain unliquidated, non-final, or final, as entry status will affect refund eligibility and timing.
    • Reconstruct Import Data: Compile and reconcile import data across customs brokers and internal systems to identify entries potentially affected by the ruling and estimate refund exposure.
    • Evaluate Contractual Exposure: Assess contractual rights and obligations, particularly where tariff costs were passed through to customers, to understand potential commercial implications if refunds are received.
    • Assess Tax and Financial Reporting Impacts: Consider whether potential refunds could affect cost of goods sold, amended tax filings, or intercompany pricing arrangements.
    • Monitor Appellate Developments: Future rulings or appeals could affect the scope and timing of refunds, making it important to stay informed as the legal process continues.

    For questions about how these developments may affect your business, our team is available to help. Frazier & Deeter continues to monitor the situation and can assist companies in evaluating entry status, modeling potential refund exposure and assessing broader implications.

    Talk to a specialist

    February 26, 2026

    Supreme Court Rules on IEEPA Tariffs: Learning Resources, Inc. v. Trump

    On February 20th, the Supreme Court issued a 6-3 decision in Learning Resources, Inc. v. Trump overturning President Trump’s “reciprocal” tariffs instituted under the International Emergency Economic Powers Act (IEEPA). According to the decision written by Chief Justice Roberts, IEEPA does not authorize the President to impose tariffs. The Court did not provide detailed guidance regarding retroactive consequences, leaving refund-related questions to lower courts and administrative processes.

    Impact of the Supreme Court Decision

    A significant potential refund opportunity now exists for companies impacted by the IEEPA tariffs; however, the pathway to refunds remains uncertain and will depend on further court proceedings and administrative guidance. The decision also creates significant uncertainty for businesses on which new tariffs may be unveiled in the coming months. President Trump announced in a press conference that his administration would be pursuing other statutes to keep tariffs in place (e.g., Section 122 of the Trade Act of 1974, Section 232 of the Trade Expansion Act of 1962, and Section 301 of the Trade Act of 1974).

    What Companies Should Do Next

    Companies may want to move quickly to review the status of customs entries that may be eligible for refunds and take steps to preserve their rights.

    Shortly after the Court’s decision, President Trump and his administration indicated that refunds would be next to impossible to administer and that litigation would be likely. Nevertheless, there are strong indications that refunds should ultimately be available.

    • Unliquidated entries: Importers should be able to file a post-summary correction (PSC) with respect to “unliquidated” customs entries; i.e., entries for which they have paid the initial estimated tariff bill, but for which U.S. Customs and Border Protection (CBP) has not yet issued the final “liquidation” order establishing the definitive amount of tariff liability. The PSC would “correct” the entry to remove the IEEPA tariff.
    • Liquidated entries: For entries that have already been subject to a liquidation order, importers should be able to either pursue an administrative protest with CBP or file a claim with the Court of International Trade (CIT).

    How Companies Can Approach Refunds and Compliance

    Navigating the IEEPA tariff ruling involves several practical considerations:

    • Calculating Refunds: Companies should quantify the exact refundable duty and statutory interest tied to unconstitutional tariffs, by entry, to support PSC, protest or litigation.
    • Reconstructing Import and Duty Data: Where records are incomplete or fragmented, companies may need to rebuild import histories to support corrections or claims.
    • Assessing State Tax Implications: The impact of refunds may extend to state income and sales/use taxes, which should be evaluated.
    • Addressing Related-Party Imports: Companies with related-party imports face additional complications: transfer pricing adjustments, valuation reconciliation and financial restatements may be required. Some will need to amend prior-year tax returns, adjust cost of goods sold, or reallocate income across jurisdictions.

    Companies impacted by the IEEPA tariffs should review their import records and take steps to preserve potential refunds. Early assessment and planning can help ensure that rights are protected and opportunities are not missed.

    Need Guidance?

    Frazier & Deeter can help companies understand the implications of the Supreme Court’s ruling, evaluate potential refunds and develop a practical approach to compliance and reporting. Contact us to discuss how to navigate this complex ruling.

    Contributors

    Dave Kim, Partner & National International Tax Practice Leader, Frazier & Deeter Advisory, LLC

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