Learning Res., Inc. v. Trump, 2026 U.S. LEXIS 714 (February 20, 2026)
The IEEPA does not authorize the President to impose tariffs. Opinion delivered by Chief Justice Roberts.
THE CHIEF JUSTICE delivered the opinion of the Court with respect to Parts I and II-A-1.
Article I, Section 8, of the Constitution specifies that “The Congress shall have Power To lay and collect Taxes, Duties, Imposts and Excises.” The Framers recognized the unique importance of this taxing power—a power which “very clear[ly]” includes the power to impose tariffs. Gibbons v. Ogden, 22 U.S. 1, 9 Wheat. 1, 201, 6 L. Ed. 23. And they gave Congress “alone . . . access to the pockets of the people.” The Federalist No. 48, p. 310 (J. Madison). The Framers did not vest any part of the taxing power in the Executive Branch. See Nicol v. Ames, 173 U. S. 509, 515, 19 S. Ct. 522, 43 L. Ed. 786, Treas. Dec. 20984.
The Government thus concedes that the President enjoys no inherent authority to impose tariffs during peacetime. It instead relies exclusively on IEEPA to defend the challenged tariffs. It reads the words “regulate” and “importation” to effect a sweeping delegation of Congress’s power to set tariff policy—authorizing the President to impose tariffs of unlimited amount and duration, on any product from any country. 50 U. S. C. §1702(a)(1)(B).
The Court has long expressed “reluctan[ce] to read into ambiguous statutory text” extraordinary delegations of Congress’s powers. West Virginia v. EPA, 597 U. S. 697, 723, 142 S. Ct. 2587, 213 L. Ed. 2d 896 (quoting Utility Air Regulatory Group v. EPA, 573 U. S. 302, 324, 134 S. Ct. 2427, 189 L. Ed. 2d 372). In several cases described as involving “major questions,” the Court has reasoned that “both separation of powers principles and a practical understanding of legislative intent” suggest Congress would not have delegated “highly consequential power” through ambiguous language. Id., at 723-724. These considerations apply with particular force where, as here, the purported delegation involves the core congressional power of the purse. Congressional practice confirms as much. When Congress has delegated its tariff powers, it has done so in explicit terms and subject to strict limits.
Against that backdrop of clear and limited delegations, the Government reads IEEPA to give the President power to unilaterally impose unbounded tariffs and change them at will. That view would represent a transformative expansion of the President’s authority over tariff policy. It is also telling that in IEEPA’s half century of existence, no President has invoked the statute to impose any tariffs, let alone tariffs of this magnitude and scope. That “‘lack of historical precedent,’ coupled with the breadth of authority” that the President now claims, suggests that the tariffs extend beyond the President’s “legitimate reach.” Nat’l Fed’n of Indep. Bus. (NFIB) v. DOL, OSHA, 595 U.S. 109, 119, 142 S. Ct. 661, 211 L. Ed. 2d 448 (quoting Free Enterprise Fund v. Public Company Accounting Oversight Bd., 561 U. S. 477, 505, 130 S. Ct. 3138, 177 L. Ed. 2d 706). The “‘economic and political significance’” of the authority the President has asserted likewise “provide[s] a ‘reason to hesitate before concluding that Congress’ meant to confer such authority.” West Virginia, 597 U. S., at 721 (quoting FDA v. Brown & Williamson Tobacco Corp., 529 U. S. 120, 159-160, 120 S. Ct. 1291, 146 L. Ed. 2d 121). The stakes here dwarf those of other major questions cases. And as in those cases, “a reasonable interpreter would [not] expect” Congress to “pawn[ ]” such a “big-time policy call[ ] . . . off to another branch.” Biden v. Nebraska, 600 U. S. 477, 515, 143 S. Ct. 2355, 216 L. Ed. 2d 1063 (BARRETT, J., concurring).
There is no exception to the major questions doctrine for emergency statutes. Nor does the fact that tariffs implicate foreign affairs render the doctrine inapplicable. The Framers gave “Congress alone” the power to impose tariffs during peacetime. Merritt v. Welsh, 104 U. S. 694, 700, 26 L. Ed. 896, Treas. Dec. 5154. And the foreign affairs implications of tariffs do not make it any more likely that Congress would relinquish its tariff power through vague language, or without careful limits. Accordingly, the President must “point to clear congressional authorization” to justify his extraordinary assertion of that power. Nebraska, 600 U. S., at 506 (internal quotation marks omitted).
• Based on two words separated by sixteen others in Section 1702(a)(1)(B) of IEEPA “regulate” and “importation,” the President asserts the independent power to impose tariffs on imports from any country, of any product, at any rate, for any amount of time. Those words cannot bear such weight and the President is reversed.
• Article I, Section 8 of the Constitution sets forth the powers of the legislative branch which provides that Congress has the power to lay and collect taxes, duties, imposts and excises.
• The power to impose tariffs is clearly a branch of the taxing power.
• The framers expected that the government, would for a long time, depend on tariffs for revenue.
• The framers of the Constitution wanted to keep the taxing power within Congress.
• The President enjoys no inherent authority to impose tariffs during peacetime.
• The government relies exclusively on the IEEPA. It reads the words “regulate” and “importation” to effect a sweeping delegation of Congress’s power to set tariff policy, authorizing the President to impose tariffs of unlimited amount and duration, on any product from any country.
