The one-paragraph version
On February 20, 2026, the Supreme Court decided Learning Resources, Inc. v. Trump (docket 24-1287), holding 6-3 that the International Emergency Economic Powers Act does not authorize the President to impose tariffs. Chief Justice Roberts wrote the majority opinion. The judgment was vacated and remanded. Two days later the administration ended collection of IEEPA duties by executive order. CBP stopped collecting on February 24, 2026 and opened the CAPE refund channel on April 20, 2026.
The opinion
The majority read IEEPA the way it is written — as a list of specific emergency economic powers that includes "regulate," "block," "prohibit," and a handful of others, but not "tariff" or "duty." Because Congress has written every prior tariff authorization explicitly — Trade Act Sections 122 and 301, Trade Expansion Act Section 232, HTSUS Chapter 99 trade-remedy headings — the omission of tariff language from IEEPA was decisive. Had Congress meant to delegate tariff authority, it would have said so, as it has said so in every other tariff statute.
The Court also observed a constitutional consideration: reading "regulate importation" to include the power to impose taxes on importation would have rendered IEEPA partly unconstitutional, because Article I, Section 9 bars taxes on exports, and the statute applies symmetrically to imports and exports. Narrow reading was available. Narrow reading was chosen.
You can read the full opinion here:
- Supreme Court opinion (24-1287), Feb 20, 2026 — PDF
- Justia — Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026)
- Oyez — Learning Resources, Inc. v. Trump (24-1287)
- Cornell LII — Supreme Court Bulletin on 24-1287
- SCOTUSblog — Learning Resources v. Trump case file
What the opinion does not say
The opinion is narrow. Three things the Court did not decide:
- How refunds work. The Court vacated the tariffs, not the duties already collected. Mechanism, eligibility, and timing of reimbursement were left to CBP and the executive branch. CBP's CAPE channel is the administrative response.
- Whether Section 232 or Section 301 are safe. Those tariffs live under different statutes with explicit tariff-authority language. They were not before the Court and are not affected.
- What the President can do next. The opinion is about IEEPA only. The administration responded by invoking Trade Act Section 122 for a 10% global surcharge, a different statute with explicit — and more constrained — tariff authority (150-day limit, 15% rate ceiling).
What CBP did in response
CBP's response was fast and technical. Timeline:
- Feb 22, 2026 — Executive order "Ending Certain Tariff Actions" terminates IEEPA duty collection. CBP issues a CSMS message the same day instructing the trade community to stop accruing IEEPA duties on entries filed Feb 24 onwards.
- Feb 24, 2026 — CBP stops collecting IEEPA duties at 12:00 AM ET. The replacement Section 122 surcharge takes effect.
- Apr 10, 2026 — CBP issues CSMS #68315804 introducing the CAPE refund process and fixing Apr 20 as the deployment date.
- Apr 14, 2026 — CBP publishes the Trade Information Notice for CAPE Phase 1 with submission format and timing details.
- Apr 17, 2026 — CSMS #68340863 ships with implementation clarifications.
- Apr 20, 2026, 08:00 ET — CAPE Phase 1 is live in the ACE Portal. Importers and brokers can submit CAPE Declarations.
How large is the refund universe
The Penn Wharton Budget Model estimated that IEEPA duties collected between Feb 2025 and Feb 2026 were in the tens of billions of dollars; subsequent secondary coverage from law-firm trade groups (Ropes & Gray, Sidley Austin, WilmerHale, Holland & Knight) cites figures in that range. Per-importer refunds vary enormously based on HTS mix, volume, and entry timing — the free calculator gives you a band specific to your numbers.
Further reading
Primary sources
- SCOTUS — Opinion PDF (24-1287)
- Congressional Research Service legal sidebar (LSB11398)
- White House — Executive order ending IEEPA tariff collection
- CBP — IEEPA Duty Refunds (official program page)
- CBP — IEEPA FAQ
- CBP — CAPE Phase 1 Trade Information Notice (PDF)
Analysis
- SCOTUSblog — Supreme Court strikes down tariffs
- Brookings — Experts on the Supreme Court's tariff decision
- Penn Wharton Budget Model — IEEPA revenue and potential refunds
- K&L Gates — Summary of the decision
- Sidley Austin — Decision and new tariff regime
- Ropes & Gray — Implications for importers
- WilmerHale — What now?
- Covington — CBP announces CAPE launch
- Norton Rose Fulbright — CBP tariff refund instructions
- Thompson Hine SmartTrade — CAPE Phase 1 confirmation
- Hogan Lovells — CBP IEEPA refund FAQs
- White & Case — Termination of IEEPA-based tariffs
- Holland & Knight — What importers need to know
- Troutman Pepper — Section 122 surcharge response
- BDO — IEEPA refund FAQs
- Forvis Mazars — CAPE processing guidance
- Cherry Bekaert — Phase I CAPE alert
All outbound links open in a new tab. We cite broadly on purpose — no single source is authoritative on both the legal and administrative sides of this ruling. Cross-referencing Supreme Court opinion (24-1287) — Learning Resources v. Trump against CBP — Trade Information Notice, CAPE Phase 1 (PDF) is the shortest path to a complete picture.
Common questions
What did the Supreme Court actually decide?
The Court held, 6-3, that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. Chief Justice Roberts wrote the majority opinion, joined by Justices Sotomayor, Kagan, Gorsuch, Barrett, and Jackson. Justices Thomas, Kavanaugh, and Alito dissented. The judgment was vacated and remanded.
Did the Court order CBP to issue refunds?
No. The opinion invalidated the tariff authority but did not address refunds or how reimbursement would operate. The refund process was established separately by CBP through the CAPE channel on Apr 20, 2026, acting on executive guidance and standard refund-authority statutes.
What is the reasoning in one sentence?
IEEPA lists specific economic powers the President can invoke during an emergency — regulate, prohibit, block — and tariffs are not on the list. Since Congress has written every prior tariff authorization explicitly, its omission from IEEPA was decisive.
Does the ruling affect Section 232 or Section 301 tariffs?
No. Those tariffs were imposed under different statutes (Trade Expansion Act Section 232 for national-security tariffs; Trade Act Section 301 for unfair-trade-practice tariffs) that explicitly authorize tariff-setting. Learning Resources is confined to the IEEPA statute.
What did the administration do next?
On Feb 22, 2026, the President issued an executive order ending collection of IEEPA duties. CBP stopped collecting IEEPA duties on goods entered for consumption on or after 12:00 AM ET, Feb 24, 2026. A new 10% global tariff under Trade Act Section 122 began the same day, with a 150-day statutory limit.