On May 29, 2025, the Court of Appeals for the Federal Circuit (CAFC) stayed the decision of the Court of International Trade (CIT) from the previous day, which had vacated both tranches of President Donald Trump’s tariffs implemented under the International Emergency Economic Powers Act of 1977 (IEEPA) (50 U.S.C. § 1701 et seq.). President Trump had invoked IEEPA to impose so-called “reciprocal” tariffs against nearly every country in the world (see Update of April 10, 2025) and specific tariffs against Canada, Mexico (see Update of March 6, 2025) and China (see Update of May 12, 2025). As a result of the stay, the two tranches of tariffs remain in effect pending the CAFC’s review of the motion to stay of the CIT’s judgment and injunction. The CIT’s per curiam decision, however, places the burden on the Trump administration to continue defending the position that IEEPA is a valid legal basis for the tariffs.

The CIT Decision

Heard by a three-judge panel (one Reagan appointee, one Obama appointee, and one Trump appointee), the CIT case consolidated two of seven lawsuits currently challenging IEEPA as a lawful means to impose tariffs—one filed by five small businesses and the other filed by Oregon (and joined by eleven other states). The CIT panel ultimately ruled that the challenged tariffs “exceed any authority granted to the President by IEEPA to regulate importation,” and laid out three key reasons for this conclusion.

The CIT panel grounded their decision in a structuralist interpretation of U.S. law, emphasizing that while IEEPA grants the President some authority to “regulate…importation,” the Constitution explicitly assigns the power to impose tariffs to Congress. Given “the Constitution’s express allocation of the tariff power to Congress,” the judges explained, IEEPA cannot be read “to delegate an unbounded tariff authority to the President.” Such a reading is necessary to “avoid constitutional infirmities” and reinforce the principle that Congress, not the President, holds the primary authority over tariffs.

The CIT panel considered the legislative intent behind IEEPA, which was enacted after the Watergate scandal to limit, not expand, presidential power. According to the panel, interpreting the statute now to allow broad tariff authority would undermine the rationale for why Congress passed IEEPA. The CIT panel acknowledged that President Trump’s reciprocal tariffs — which were intended to address trade imbalances, a type of balance-of-payments deficit — could potentially proceed under Section 122 of the Trade Act of 1974; this provision, however, only allows for emergency tariffs up to 15% and only for 150 days (i.e., about five months). After that time period expires, Congress must approve any extension.

The CIT panel embraced a textualist argument to address the specific tariffs imposed against Canada, Mexico, and China, which President Trump justified on the grounds that these countries were failing to “arrest, seize, detain, or otherwise intercept” drug trafficking organizations, human traffickers, and criminals at large. The CIT pointed out that any measures undertaken pursuant to IEEPA must “deal with an unusual and extraordinary threat,” but the phrase “deal with” necessitates “a direct link between an act and the problem it purports to address.” The panel found that “Customs’s collection of tariffs on lawful imports does not … relate to foreign governments’ efforts to arrest seize, detain, or otherwise intercept” bad actors.

The CIT panel concluded that “the challenged Tariff Orders are unlawful as to Plaintiffs [as] they are unlawful … to all,” and issued a nationwide injunction to halt the tariffs—marking a significant limitation on the President’s ability to use IEEPA as a tool for imposing tariffs.

Tariffs Under Other Statutes Not Affected

This CIT ruling does not invalidate or otherwise impact tariffs implemented by President Trump under Section 301 of the Trade Act of 1974 and under Section 232 of the Trade Adjustment Act of 1962.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Michelle Li Michelle Li

Michelle focuses her practice on assisting clients in a wide range of industries with trade remedy proceedings. Her experience includes representing clients before the U.S. Department of Commerce, U.S. International Trade Commission, U.S. Court of International Trade, and U.S. Court of Appeals for…

Michelle focuses her practice on assisting clients in a wide range of industries with trade remedy proceedings. Her experience includes representing clients before the U.S. Department of Commerce, U.S. International Trade Commission, U.S. Court of International Trade, and U.S. Court of Appeals for the Federal Circuit. She also advises on import entry clearance and other customs and importation issues involving food, drug, medical, and tobacco products regulated by the FDA and consumer products regulated by the U.S. Consumer Product Safety Commission.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.