The Supreme Court tariff ruling explained: what Learning Resources v. Trump decided, and what it left to CBP
Published Sep 16, 2026
Page updated Oct 10, 2026
The decision
Learning Resources, Inc. v. Trump, No. 24-1287, decided together with Trump v. V.O.S. Selections, Inc., No. 25-250, was argued on November 5, 2025 and decided on February 20, 2026. The syllabus states the holding in one line: "IEEPA does not authorize the President to impose tariffs." The vote on the judgment was 6–3. Chief Justice Roberts wrote for the Court; Justices Gorsuch and Barrett concurred; Justices Kagan and Jackson concurred in part and in the judgment; Justice Thomas dissented; Justice Kavanaugh dissented, joined by Justices Thomas and Alito.
The Court affirmed the Federal Circuit's en banc decision of August 29, 2025 in V.O.S. Selections and vacated the D.C. district court judgment in Learning Resources with instructions to dismiss for lack of jurisdiction (the Court of International Trade has exclusive jurisdiction over such cases).
What the opinion does not say
Nothing about refunds. The majority does not address how the roughly $166 billion collected should be returned. The Kavanaugh dissent says: "As was acknowledged at oral argument, the refund process is likely to be a 'mess.'" It also says that the Court "says nothing today" about whether and how the Government should return the money. Everything that followed — CAPE, the Court of International Trade's orders, the Government's appeal — is downstream of that silence.
What happened next (dated)
| Date | Event | Source |
|---|---|---|
| Feb 20, 2026 | Executive Order 14389 ends the IEEPA tariff actions; Proclamation 11012 imposes a Section 122 10% surcharge | White House |
| Feb 24, 2026, 12:00 a.m. ET | CBP stops collecting IEEPA duties; Section 232 and 301 unaffected | CSMS 67834313 |
| Mar 2, 2026 | Federal Circuit issues its mandate to the CIT | CSMS 68340863 |
| Mar 6, 2026 | CBP tells the CIT: 330,000+ importers, 53 million entries, ≈$166 billion | CBP declaration |
| Mar 4 – Apr 17, 2026 | CIT orders refunds for all importers; the Apr 17 order includes finally liquidated entries | CSMS 68340863 (Mar 4, Apr 7); reported for Apr 17 |
| Apr 20, 2026 | CAPE Phase 1 opens | CSMS 68396594 |
| June 2026 | Government appeals the universal-refund order to the Federal Circuit | reported |
| Jul 15–17, 2026 | CIT orders reliquidation for plaintiffs' finally liquidated entries | CIT order ECF 46; reported for Jul 17 (made public Jul 21) |
| Aug 21, 2026 | $132.5 billion accepted, $106.6 billion sent for payment | CBP declaration (reported) |
| Sep 11, 2026 | about $134.7 billion accepted, about $122 billion (including interest) certified to the Treasury | CBP declaration of Sep 15 (reported) |
The status tracker keeps this timeline current with a source on each row.
What it means for an importer
If you deposited IEEPA duties, you have a claim. How you collect depends on the liquidation status of each entry, not on the ruling itself: CAPE for unliquidated and recently liquidated entries; a court order, a protest or a suit for finally liquidated ones. The eligibility checker sorts your entries into those buckets.
General information from public sources, not legal advice. Checked October 8, 2026.
Sources
- Supreme Court opinion, Learning Resources, Inc. v. Trump, No. 24-1287 (Feb 20, 2026) — checked Oct 8, 2026
- Federal Circuit en banc opinion, No. 25-1812 (Aug 29, 2025) — checked Oct 8, 2026
- EO 14389 — Ending Certain Tariff Actions (Feb 20, 2026) — checked Oct 8, 2026
- CBP CSMS 67834313 — collection ends Feb 24, 2026 — checked Oct 8, 2026
- GHY — CBP CAPE refund progress (Sep 11 figures from CBP's Sep 15 declaration; updated Oct 5, 2026; reported) — checked Oct 8, 2026
Frequently asked questions
›Did the Supreme Court order refunds?
No. The majority opinion does not address refunds. Only Justice Kavanaugh's dissent discusses them, calling the process likely to be a 'mess'. Refund mechanics were left to CBP and the Court of International Trade.
›Which tariffs did the ruling cover?
Only tariffs imposed under IEEPA: the China, Canada and Mexico 'fentanyl' tariffs, the reciprocal tariffs, and the Brazil and India actions. Section 232 (steel, aluminum, autos, copper and others) and Section 301 tariffs were not part of the case and continue.
›What replaced the IEEPA tariffs?
A Section 122 10% surcharge that Proclamation 11012 set to run from February 24 to July 24, 2026; Section 301 forced-labor tariffs on 60 economies from July 24, 2026; and Section 338 tariffs on designated Canadian goods from August 22, 2026 (date reported). None are refundable through CAPE.
This site provides general information from public sources, not legal, tax or customs advice.