On November 5, 2025, the United States Supreme Court heard arguments in the case Learning Resources, Inc. v. Trump. This case has the potential to be one of the most influential cases before the Supreme Court in years, and it could drastically expand the traditional understanding of presidential power over economic policy and, more specifically, tariffs. This article provides helpful context for understanding this important case through an overview on the following topics: (1) the Trump Tariffs being challenged in the current lawsuit; (2) the traditional authority to impose tariffs in the United States; (3) the International Emergency Economic Powers Act (the law President Trump relies on in support of his tariffs); (4) the current legal challenge to the Trump Tariffs under the IEEPA; and (5) the likely result of the lawsuit.
President Trump Unilaterally Imposes Tariffs in the Face of Opposition
In early 2025, President Donald Trump’s administration issued a series of proclamations and executive orders announcing substantial tariffs on imports from many countries. Although tariffs are not uncommon, what made these tariffs unusual is that they were not approved by the United States Congress. Instead, they were imposed unilaterally by President Trump. President Trump’s administration defended these tariffs under several existing laws, such as Section 232 of the Trade Expansion Act (permitting presidential tariffs for specified national security reasons) and the International Emergency Economic Powers Act (permitting economic sanctions on an emergency basis).
The Trump Tariffs were met with immediate opposition and several lawsuits challenging the tariffs. The most significant lawsuit is a consolidated case styled Learning Resources, Inc. v. Trump (and related petitions consolidated before the Supreme Court). This case challenges the Trump Tariffs that were imposed under the International Emergency Economic Powers Act (IEEPA) and asks a basic but far-reaching question: may the President use the IEEPA to impose broad, economy-wide tariffs on imports?
The Trump Administration has defended its tariffs under the IEEPA by claiming that the United States is facing economic emergencies in the form of massive trade deficits, cross-border migration, and the flow of illicit drugs—especially fentanyl—into the United States. The opponents of the Trump Tariffs argue that the Trump Tariffs are not authorized by the IEEPA, a statute they argue authorizes only limited economic sanctions (and not necessarily tariffs) on a narrower, emergency basis.
The disputes raised by the parties in this case are significant because the Trump Administration is advancing novel theories that would expand the understanding of presidential authority over economic policy, especially over tariffs and taxation.
Traditional authority to impose tariffs under American law
The United States Constitution places trade and tariff power primarily with Congress. Article I, Section 8 of the Constitution gives Congress the power “to lay and collect Taxes, Duties, Imposts and Excises.” From the founding of the United States (in the eighteenth century) through the twentieth century, federal tariff policy has been made by Congress (although Congress also delegates limited discretion to the executive for certain, narrowly framed tasks (for example, administration and classification of imports by the U.S. Customs Service)).
However, in modern times, Congress has increasingly been more willing to delegate its tariff authority to the President. For example, Section 232 of the Trade Expansion Act (and related statutes) allows the President to impose tariffs or restrictions on certain imports when the Department of Commerce finds a threat to national security and the President decides action is warranted. Separately, Congress has passed specific statutory delegations for particular trade remedies (antidumping, countervailing duties) and for emergency authorities that are typically tethered to specific findings, procedures, or limited subject-matter scopes. These carve-outs are the historical exception to the general rule that tariff-setting is legislative authority.
IEEPA: history, purpose, and historical uses
The International Emergency Economic Powers Act, passed in 1977, was designed to replace portions of the older Trading With The Enemy Act and to create a statutory framework that would allow the President to block property and impose economic sanctions in response to declared foreign emergencies. The IEEPA authorizes the President to “investigate, regulate, or prohibit, any transactions in foreign exchange, transfers of credit, or payments between, by, through, or to any banking institution,” and more broadly to “deal with” property or interests of foreign powers or persons, where a national emergency has been declared with respect to unusual and extraordinary threats. Congress included reporting requirements, limits on scope (for example, a prohibition on regulating informational and certain personal communications), and a mechanism (the National Emergencies Act) for Congress to terminate or oversee emergency declarations.
Historically, the IEEPA has been the principal statutory tool for modern sanctions programs, including programs for freezing assets of foreign actors, prohibiting trade with named countries or persons, and blocking certain classes of financial transactions. Presidents of both parties have used the IEEPA to sanction regimes (e.g., Iran and North Korea), terrorist actors, and foreign individuals. The law has also been used to cut off financial flows and restrict access to the U.S. financial system.
However, while the IEEPA authorizes broad economic measures, it has not previously been used as a general authorizing vehicle to impose across-the-board import duties (tariffs) as if it were a replacement for Congress’s taxing and tariff powers.
The challenge in Learning Resources — legal claims and the lower court rulings
As explained above, in early 2025, the Trump administration announced substantial tariffs on imports from many countries. These tariffs including over a broad set of product categories. The administration invoked national emergencies and pointed to the IEEPA as the statutory basis for imposing the duties without seeking new legislation from Congress.
Small businesses and importers (including Learning Resources, a company that imports educational products) promptly sued, arguing that the tariffs exceed the President’s statutory authority and that Congress had not authorized the executive to impose tariffs under IEEPA. The plaintiffs’ complaints raise two central legal theories:
- Statutory limits: the IEEPA’s text does not explicitly authorize the imposition of import duties or taxes. Plaintiffs argue that Congress knows how to delegate tariff authority (for example, via Section 232 or other trade statutes) and did not do so in the IEEPA. For this reason, Plaintiffs argue, the President cannot use the IEEPA as a loophole to set tariffs that are, effectively, revenue-raising taxes or import taxes that Congress alone retains the power to authorize.
- Constitutional non-delegation (and major questions): Even if the statute could conceivably be read to authorize tariffs, plaintiffs contend that such a sweeping delegation would be unconstitutional because Congress may not (consistent with Article I) hand over core taxing and tariff powers without a clear statement and intelligible principle. Plaintiffs also invoked the Supreme Court’s recent “major questions” jurisprudence (a principle under which courts read ambiguous statutes narrowly rather than impute sweeping regulatory power).
A federal trial court ruled on this case in May 2025, concluding that the IEEPA did not authorize the tariffs. Multiple district courts in related cases have also entered rulings finding that the administration’s IEEPA-based tariffs were unlawful, concluding that IEEPA did not grant the President blanket tariff-setting authority and that Congress had not clearly authorized the extraordinary step of letting the executive impose economy-wide import taxes. One three-judge panel of the Court of International Trade (and later a federal appeals panel) granted summary judgment to plaintiffs and enjoined the tariff orders. However, some rulings were stayed pending appeal. The government has pursued an expedited route to the Supreme Court, both by appeal and by petitioning for review.
Likely result in the Supreme Court — legal stakes and predictive assessment
The Supreme Court heard oral argument in this case on November 5, 2025. Although the Supreme Court may not issue a ruling for months, the questions asked by the Court during oral argument suggest that the Court is likely to strike down the tariffs. Indeed, several factors favor the challengers. First, the historical purpose and practice surrounding the IEEPA suggest that Congress did not intend the IEEPA to function as a general tariff-making statute. This is significant because courts confronted with a novel and economically seismic claim of authority often apply the major-questions principle to require clear congressional authorization. Second, the constitutional text and precedent emphasize that taxation and tariff authority are core legislative powers. This is important because the Supreme Court has recently shown that it is skeptical of broad delegations of authority to the executive branch. So it is likely that the Court will be reluctant to read a sanctions statute as implicitly transferring broad tariff power. Finally, several lower court rulings have already rejected the administration’s reading, and those opinions relied on well-trodden interpretive canons (textualism plus historical practice).
However, if the Supreme Court does uphold the tariffs, it will likely do so based on a practice in past cases to defer to the political branches on foreign affairs and national security. At oral argument, the Trump Administration argued that the IEEPA was designed for emergencies precisely like the ones the administration declared and that courts should be cautious about second-guessing the President on foreign-economic threats. If a majority of justices view the tariffs as a form of emergency economic regulation squarely within the statute’s plain language, they may uphold the measures.
Conclusion
Learning Resources, Inc. v. Trump asks the Supreme Court to decide whether the IEEPA, an emergency sanctions statute, can be used as an all-purpose delegation to impose economy-wide tariffs. The case forces a collision between two traditions: deference to the President on foreign-economic emergencies, and the constitutional command that taxing and tariff power belong to the people’s representatives in Congress. The Court’s decision will do more than resolve a revenue dispute for a handful of importers. Instead, it will define how far the executive may go in using emergency economic statutes to reshape U.S. trade policy without express congressional authorization. Given the statutory history and the Court’s recent interpretive tendencies, a ruling narrowing the IEEPA’s reach — or rejecting the administration’s tariff theory — would be the outcome most consistent with existing doctrine.
This article does not constitute legal advice but presents only a general overview of common legal principles. Those principles may vary by jurisdiction. You should consult legal counsel with regard to your specific situation. No attorney-client relationship is formed by the publishing of this article.
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