On March 17, 2026, Chief Judge Mark Barnett of the U.S. Court of International Trade (“CIT”) issued an order of reassignment transferring cases seeking refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”) to CIT Senior Judge Richard Eaton.  Chief Judge Barnett’s order effectively ratified Judge Eaton’s March 4, 2026 order in Atmus Filtration declaring “I am the only judge who will hear cases pertaining to the refund of IEEPA duties” (see Update of March 4, 2026).

Among the cases reassigned to Judge Eaton is V.O.S. Selections, which had previously been consolidated and adjudicated by the U.S. Supreme Court and was widely viewed as the putative lead case to address IEEPA tariff refunds.  (For background on the U.S. Supreme Court decision, see Update of February 20, 2026.)  V.O.S. Selections and all the other reassigned cases were promptly stayed by Judge Eaton at the time of Chief Judge Barnett’s reassignment order.  Atmus Filtration is now the lead case.  On March 18, 2026, the plaintiff filed a motion requesting the establishment of a master case and a Plaintiffs’ Steering Committee to “ensure that the C[IT] receives the benefit of insight from experienced customs practitioners representing a range of claimants on the nuanced legal and procedural questions at hand.”  According to the motion, “Plaintiff is not prepared to speak for all plaintiffs in the IEEPA Tariff Cases, let alone for all affected importers[.]”  Within hours of the motion, however, Judge Eaton denied it without comment, issuing a brief order: “Upon consideration of Plaintiff’s Motion for Expanded Case Management Procedures…it is hereby ORDERED that the motion is denied.”  Today, another closed status conference with the plaintiff and the federal government defendants was scheduled.

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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 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.