Learning Resources, Inc. v. Trump, 607 U.S. 229 (2026), is a decision of the Supreme Court of the United States in which the Court held that the International Emergency Economic Powers Act (IEEPA), an economic sanctions law, does not authorize the president to unilaterally set tariffs. The ruling vacated many of the tariffs implemented during the second Trump administration.
In February 2025, President Donald Trump announced tariffs on imports from Canada and Mexico, and separately from China, citing the IEEPA as the statutory authority for doing so. After implementing other tariffs citing different statutory authorities, Trump announced the global Liberation Day tariffs also citing the IEEPA the following April. Multiple lawsuits from affected companies and U.S. states were filed shortly after this announcement, including both Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections, Inc., challenging the president's authority to issue tariffs under IEEPA.
In Learning Resources, the District Court for the District of Columbia ruled the tariffs were unconstitutional in May 2025. In Trump v. V.O.S. Selections, the United States Court of International Trade (CIT) ruled in May 2025 that the president does not have the authority to use the IEEPA to set tariffs in this way, and permanently enjoined the government from enforcing them. The CIT's ruling was upheld on appeal by the en banc Federal Circuit Appeals Court in August 2025. In both cases, the lower courts stayed their injunctions to allow Trump to appeal the rulings to the Supreme Court.
The Supreme Court granted both petitions in September and consolidated them into a single case. The Court expedited scheduling of oral arguments, which were heard on November 5, 2025. Court observers believed a majority of the justices expressed skepticism towards the government's rationale for the tariffs during the oral session. In its opinion of February 20, 2026, the Court decided that this matter is within the exclusive jurisdiction of the CIT, and ordered the dismissal of the Learning Resources case from the District of Columbia court. The Court affirmed the CIT ruling in V.O.S. Selections against the tariffs, though did not rule on the manner of tariff repayment. Since the decision, refunds have been issued by the United States Customs and Border Protection to those businesses that had paid IEEPA tariffs, while Trump has enacted other tariffs through limited routes previously passed into law by Congress, such as through the Trade Expansion Act and the Trade Act of 1974.
Background
During his 2024 presidential campaign, Donald Trump stated his intent to place heavy tariffs on China while applying tariffs to most other imports, asserting these were needed to have countries improve their efforts to stop the entry of illegal drugs like fentanyl into the US, as well as to stem the flow of undocumented immigrants. Trump likened the need for tariffs to recreate the successes of the Gilded Age in the late 19th century under William McKinley.
Trump enacted executive orders 14193, 14194, and 14195 on February 2, 2025, for tariffs on Canada, Mexico, and China, respectively, citing his ability to do so under the International Emergency Economic Powers Act (IEEPA). On April 2, 2025, Trump announced further "Liberation Day" tariffs on many countries and products as part of Executive Order 14257 asserting his authority to do so under the IEEPA. Trump argued that there were numerous trade deficits that were unfair to the United States and threaten national security, and declared an economic emergency to justify the use of the IEEPA to correct them. Under the new tariff plan, nearly all incoming goods were set to a 10% tariff, with about sixty additional countries set at higher tariff rates. Further, Trump stated his intent to use "reciprocal tariffs" calculated based on countries' trade surpluses with the United States. Trump had pushed for tariffs alongside his "Big Beautiful Bill" passed by Congress in July 2025 which significantly cut government revenue from taxes but with more government spending, with the tariffs intended to make up the difference. The Trump administration has also said the tariffs would help deal with the $37 trillion federal debt, and allows a point of leverage in foreign relations. The tariffs did not come into effect until July 2025, during which the Trump administration secured trade agreements with some countries including Japan and the European Union, reducing the tariff rate applied in exchange for either investments into the US or importing more US goods.
The tariff plan was met with harsh criticism from multiple sectors. World leaders from multiple countries urged Trump to back off the tariff plan, with the European Union's president Ursula von der Leyen saying they would be a "major blow to the world economy". Economic experts also were critical of the tariff plan with concerns on the flawed calculations used to justify the tariff rates. Business lobbying groups including the United States Chamber of Commerce and the Business Roundtable sought relief from the Trump administration to lessen the impact of the tariffs on businesses. Small businesses were hardest hit by the tariffs; compared to large companies that had sufficient on-hand capital to stock up on imports prior to enforcement of the tariffs, many small businesses had little leeway to prepare, and many had to cut back on profit and plans for expansion due to the tariffs.
Lower court history Multiple lawsuits were filed in wake of Trump's Liberation Day tariff announcement, but the V.O.S. Selections was one of the first filed and had progressed the farthest; James Fanelli of The Wall Street Journal said "Other challenges have been filed in the court and in federal district courts around the country, but the V.O.S. case is front and center so far." In addition to Learning Resources and V.O.S. Selections, there were other similar lawsuits. In April 2025, twelve US states led by Oregon filed a similar suit in the Court of International Trade, arguing that Trump did not have the authority to use the IEEPA to set tariffs.Kayla Epstein, "A dozen US states sue to halt Trump's tariffs", BBC News, April 23, 2025. The states' case was consolidated with that of the V.O.S. Selections' case.
These cases do not challenge another route for the president to set tariffs under Section 232 of the Trade Expansion Act, which allows the president to establish tariffs in the interest of national security. Trump has used this during his second administration to set tariffs on aluminum and steel imports, among other goods.
Learning Resources v. Trump On April 22, 2025, Learning Resources and Hand2mind, two family-owned educational toy manufacturers, sued Trump in the United States District Court for the District of Columbia. In an interview with CBS News, Learning Resources' chief executive, Rick Woldenberg, argued that Trump's tariffs would negatively affect his business and the US economy, citing that their costs to tariffs had risen by a 44-fold increase.
A coalition of experts filed an amici curiae brief in support of the plaintiff for Learning Resources, in addition to a similar one for V.O.S. Selections, stating "The powers to tax, to regulate commerce, and to shape the nation's economic course must remain with Congress. They cannot drift silently into the hands of the President through inertia, inattention, or creative readings of statutes never meant to grant such authority. That conviction is not partisan. It is constitutional. And it strikes at the heart of this case." The brief, co-authored by Michael W. McConnell and Joshua Claybourn, brought together "big-name constitutional law scholars across the political spectrum" according to Reason, and included legal scholars Steven Calabresi, Harold Koh, Richard Epstein, Michael W. McConnell, and Gerard Magliocca, and former government officials Michael Mukasey, George Allen, and Chuck Hagel. The filing, dubbed the McConnell/Claybourn brief, was cited by Vox as one of the plaintiffs' two significant advantages, noting that co-signer John Danforth is a mentor to Justice Clarence Thomas and gave Thomas his first job out of law school. According to Adam Liptak of The New York Times, the amici brief was considered instrumental in the case's proceedings. McConnell would later transition to serve as counsel to the plaintiffs in V.O.S. Selections.
Judge Rudolph Contreras ruled on May 29, 2025, that Trump's tariffs were unlawful, but limited his order to the plaintiffs and delayed it until an appeal could be heard. Trump appealed to the D.C. Circuit Court of Appeals by June 3, leading judge Contreras to extend the stay on his order while the case was litigated there.
While the case progressed in the appeals court, Learning Resources filed for a motion to expedite directly to the Supreme Court, bypassing the appeals court, along with a writ of certiorari on June 18, 2025. The Supreme Court rejected the expedited request two days later without comment. In July, solicitor general D. John Sauer argued that the justices "should not leapfrog" the proceedings in the appeals court.
V.O.S. Selections, Inc. v. Trump Court of International Trade In V.O.S. Selections, the plaintiffs, consisting of five small businesses which were facing potential bankruptcy due to the tariffs, filed suit against the government on April 14, 2025, in the United States Court of International Trade (CIT), a judicial venue for civil actions related to the government's trade regulations. The businesses were represented by the Liberty Justice Center and Ilya Somin, a law professor at George Mason University. The plaintiffs argued that the administration had improperly used the IEEPA to impose tariffs that were not authorized by that law. Somin said that while the IEEPA had previously been used by other presidents in sanctions against other countries or to freeze assets of foreign terrorists, no previous president used the law to simply set tariff rate, and that Trump's imposition of the tariffs was "an enormous abuse of power, and it still needs to be stopped". Jeffrey Schwab, senior counsel at Liberty Justice Center said:Our system is not set up so that one person in the system can have the power to impose taxes across the world economy. That’s not how our constitutional republic works...
The Court denied a motion for a temporary restraining order on April 25, 2025, but ordered the Trump administration to respond to the plaintiffs' motions for a preliminary injunction and summary judgment. The Court set a briefing schedule and hearing to rule on plaintiff's motion for a preliminary injunction to enjoin the implementation of the Liberation Day tariffs.
The three judge panel, consisting of judges Timothy Reif (a Trump appointment), Gary Katzmann (an Obama appointment), and Jane Restani (a Reagan appointee), heard the case on May 13, 2025. Plaintiffs were represented by Jeffrey M. Schwab of the Liberty Justice Center, while Eric J. Hamilton of the US Department of Justice defended the government's position.
The Trump administration argued that federal courts upheld use of the Trading with the Enemy Act of 1917, to which the IEEPA was an amendment, by the Nixon administration in response to the economic impact from the ending of the Bretton Woods system in August 1971.