Learning Resources, Inc. v. Trump - Justice Jackson

On April 2, 2025, President Donald Trump declared a national emergency, claiming that U.S. goods trade deficits have led to the deterioration of the domestic manufacturing sector as factories have closed or moved abroad. He asserts that this decline has increased risks for the U.S.’s supply-chains, leaving the “defense-industrial base dependent on foreign adversaries.” On the grounds that foreign countries have exacerbated the trade deficit with harmful policies, President Trump controversially invoked the International Emergency Economic Powers Act of 1977 (IEEPA). Following this assertion of authority, Trump imposed a 10% tariff on all countries — with higher rates imposed on countries with which the U.S. has the largest trade deficits — with a shaky, open-ended termination date. The recent Supreme Court decision on February 20, 2026 held in a 6-3 ruling that IEEPA does not grant the president the powers to impose such tariffs. Providing a strong argument in favor of the majority opinion, Justice Ketanji Brown Jackson took a unique and comprehensive approach that sought to avoid dependence on the controversial major questions doctrine while grounding her opinion on explicit, textual evidence found in legislative history.

Challenging the use of IEEPA, Learning Resources, a children’s educational-toy company, sued the Trump administration in the United States District Court for the District of Columbia on April 22, 2025. The District Court ultimately held that IEEPA did not grant the authority to impose tariffs, and they granted a preliminary injunction for the plaintiffs after denying transfer to the United States Court of International Trade (CIT). Also challenging the Trump administration was plaintiffs V.O.S. Selections, who sued in the CIT. Both cases were consolidated and argued in front of the Supreme Court on November 5, 2025, which ultimately
held that IEEPA did not grant authority to the President to impose tariffs. Further details on the specifics of the case, the prominent arguments, and timeline can be found in a previous article. Justice Ketanji Brown Jackson agreed that IEEPA did not grant the aforementioned powers, but interestingly, she alongside Justices Kagan and Sotomayor assert that the Court does not need to refer to the Major Questions Doctrine to support the result. Rather, ordinary statutory interpretation provides sufficient grounds to strike down President Trump’s use of IEEPA. The major questions doctrine is a principle that requires “clear congressional authorization” for federal agencies to enact policies of “great economic or political significance.” In refraining from referring to this doctrine, Justice Jackson takes an active stance in limiting the usage of the contentious doctrine. The doctrine is often seen as problematic for being too flexible, since the criteria for what makes a question “major” is unclear, and for granting the judicial branch more power by allowing them to invalidate significant federal actions. Although utilizing this doctrine could be strong grounds for striking down Trump’s use of IEEPA, it would set a precedent for future cases to more freely use this doctrine, which Justice Jackson aimed to avoid. While agreeing with the majority opinion in opposing the expansion of presidential powers under IEEPA, Justice Jackson also heavily prioritizes the methodology of limiting such authority. In her concurrence joined by no other members of the Court,Justice Jackson continues to advocate for an emphasis on legislative history in statutory interpretation and as applied to this case. She points to the legislative history of IEEPA and the Trading with the Enemy Act of 1917 (TWEA) — “IEEPA’s predecessor statute” — and highlights the 1941 TWEA amendment that included the language of “regulate… importation.” Importantly, this language was sustained in IEEPA. However, the Senate and House Reports that accompanied IEEPA in 1977 revealed that the inclusion of “regulate… importation” was solely to grant presidential authority during emergencies to “‘to control or freeze property transactions where a foreign interest is involved.’
S. Rep. No. 95– 466, p. 5 (1977).” In essence, Congress deliberately included this language in IEEPA to grant the authority to freeze foreign assets and property in times of emergency. She expressly states that tariffs are beyond the scope of what IEEPA authorizes, since they are taxes on imports. Tariffs are used to generate revenue by taking a portion of money from private party transactions, so tariffs cannot be used to control foreign property. In addition, Justice Jackson cites United States v. American Trucking Assns., Inc., 310 U. S. 534, 542 (1940) to assert that the role of the Court is to interpret the will of Congress and to provide judicial interpretation rather than enact legislation. Through this reasoning, Justice Jackson stood juxtaposed to the dissenting opinion of Justice Kavanaugh, who declined to use legislative history.

Although the 6-3 majority held that IEEPA did not grant the President the authority to impose tariffs, it seems there are contentions as to how such a decision was reached. The primary disputes among the majority seemed to lie in whether or not to use the major questions doctrine. Among these challenges, Justice Jackson stands out for her refusal to utilize the doctrine and for her focus on legislative history. Rather than relying solely on similar decisions found in precedents, she hones in on the actual legislative origins of IEEPA—using the 1941 TWEA amendment and 1977 House and Senate reports that detail the power authorized by IEEPA—to provide textual evidence for President Trump’s unlawful use of tariffs. This case reveals that Justice Jackson stays steadfast in her rigorous statutory and textual approach to judicial interpretation. While Jackson holds steady by not having to incorporate the controversial major questions doctrine, it does beg the question of how well her emphasis on legislative history will stand up in the long run. As the Trump administration continues to challenge its limits on executive authority, it may take more than the unpredictable approach of legislative history to meet these challenges in the Court.