Learning Resources, Inc. v. Trump (ROBERTS Opinion)

Facts of the Case:
Almost immediately upon taking office for a second term, President Donald Trump enacted sweeping tariffs under the International Emergency Economic Powers Act (IEEPA), sparking public scrutiny over whether he had been authorized to do so. In a series of executive orders, the president’s tariffs sought to address two primary concerns: 1) illicit drug manufacturing and trafficking, specifically fentanyl, from Canada (Executive Order No. 14193), Mexico (Executive Order No. 14194), and China (Executive Order No. 14195), which the administration characterized as creating a public health crisis; and 2) the looming trade deficit posing an “unusual and extraordinary threat” to Americans’ economic prospects (Executive Order No. 14257). Declaring such circumstances national emergencies, President Trump invoked his powers under IEEPA to address such concerns.
Petitioners, Learning Resources, Inc. and V.O.S Selections, Inc., who were granted summary judgment to be incorporated under the ultimate Learning Resources, Inc. v. Trump decision, are both small businesses that operate domestically but import and produce products abroad, including in China, such that complying with President Trump’s tariffs would unsustainably increase import costs. Thus, Learning Resources, Inc. filed suit in the U.S. District Court for the District of Columbia on April 22, 2025, and V.O.S. Selections, Inc. filed suit in the Court of International Trade on April 14th, respectively. Learning Resources claimed that IEEPA does not confer unilateral power to authorize any tariff. In their petition for certiorari, they cited that “No President in IEEPA’s history has relied on that law to issue any tariff” and presented a separation of powers question related to Congressional power to regulate tariffs as understood in the U.S. Constitution (art. I, § 8, cl. 1). On May 29, 2025 they were granted a preliminary injunction holding that the tariffs were imposed illegally and were existentially threatening to the petitioner. Days later, however, the government appealed, and the injunction was stayed pending appeal. The plaintiffs then filed a petition for certiorari before judgment.
On September 5, 2025, the Supreme Court granted cert. before judgment, consolidating V.O.S. Selections among other petitioners and setting oral argument for Wednesday, November 5, 2025. On February 20th, 2026, Chief Justice Roberts delivered a three part opinion of the Court: with respect to Part I, Part II-A-1, and Part II-B, Justices Sotomayor, Kagan, Gorsuch, Barrett, and Jackson joined in a 6-3 majority, holding that the IEEPA did not grant President Trump tariff authority; with respect to Part II-A-2 and Part III, Gorsuch and Barrett joined this plurality — but not majority — opinion, arguing for consideration of the Major Questions Doctrine over whether “clear congressional authority” is necessary for significant presidential actions. Gorsuch and Barrett also filed concurring opinions, while Kagan filed an opinion concurring in part and judgment, joined by Sotomayor and Jackson, who produced her own opinion concurring in part and judgment. Justice Thomas authored a dissenting opinion, as did Justice Kavanaugh, who was joined by Thomas and Justice Alito.

Robert’s Opinion:
Part I: Framing the Controversy
In Part I, Roberts provides a history of President Trump’s tariff regime at question in Learning Resources and the procedural posture of the consolidated cases. While Roberts goes on to ultimately condemn the validity of the tariff policy, his tone is notably restrained within the opinion. Yet, Learning Resources is an escalation of the complex, and at times contradictory, relationship that Roberts maintains with the Trump administration — Roberts having authored the majority opinion in Trump v. United States, which addressed the scope of presidential immunity, but also having recently condemned him publicly for his calls for judicial impeachment over deportation injunctions.
In the framing of Learning Resources, however, Roberts presents the tariff question as a dispute over statutory authorization rather than a political controversy. In doing so, the Court is postured as a structural umpire rather than a partisan arbiter, removing the question of presidential motive and focusing on the delegated power question. Moreover, this mirrors Robert’s minimalist and prudentialist attitude, limiting decisions at the direct question at hand to protect the Court’s legitimacy, particularly when dealing with an administration surrounded with significant controversy.
Part II-A-1: The Constitution Says Tariffs are Taxation
In Part II-A-1, joined by the majority, The Chief Justice grounds his analysis in the view that tariffs constitute taxation rather than a regulatory measure under IEEPA, citing Congress’s taxation rights under the Constitution. Roberts begins by looking at the particular constitutional language surrounding taxation, and tariffs by extension: “The Congress shall have Power To lay and collect Taxes, Duties, Imposts and Excises… all Duties, Imposts and Excises shall be uniform throughout the United States” (art. I, § 8, cl. 1).
As Roberts sees it, the language itself clearly extends the power of taxation to Congress, and Congress alone. Paired with historical context, Roberts cites Alexander Hamilton and the Federalist Papers to assert the central importance of taxation as reserved for the legislative body, underlining the historic understanding of “duties” and “imposts” as exclusively congressional. Robert’s central claim is that the Framers vested Congress with taxation power due to its instrumental role in sovereignty and governmental accountability. As a result, the unilateral imposition of sweeping tariffs by a president under an emergency statute is not justifiable and threatens the constitutional allocation of powers.
Moreover, Roberts takes issue with the government’s attempt to conflate the words “regulate…importation” to grant taxation power. Representatives of the federal government argued that to “regulate…importation” necessarily includes the implementation of tariffs as a regulatory tool, deeming it an extension of IEEPA’s measures. Roberts largely responds by reasserting that the executive’s argument obscures the constitutional and historical context. Moreover, authorizing the president to set tariff policy denies that regulation and taxation impose distinct financial burdens that the Constitution strictly separates.
Ultimately, in Part II-A-1, Roberts relies on the structure and nature of tariffs, grounded historically and constitutionally, to inform his rejection of using IEEPA to expand the executive’s authority over tariff policy.
Part II-A-2: The Major Questions Doctrine: The Power of Congress
Joined only by Justices Gorsuch and Barrett, Part II-A-2 is a distinct shift, moving into a doctrinal question; namely, whether the Major Questions Doctrine is applicable to this case.. Here Roberts argues that even if IEEPA were ambiguous, separation of powers and legislative intent indicate IEEPA never conferred presidential tariff power, as the economic significance of such measures necessarily would require “clear congressional authority.”
Roberts applies major questions analysis arguing that the IEEPA’s language is not concrete enough to justify an expansion of executive authority to include tariff powers which significantly affect a nation’s economy. Moreover, the plurality’s invocation of major questions analysis suggests an interesting recalibration of executive power, mentioning cases such as Biden v. Nebraska (2022) where again the power of Congress was given deference over the scope of the executive. Yet, Roberts again is tempered, not framing such reasoning as anti-regulation but rather as pro-textualism and pro-certitude in matters of extreme economic importance. Such framing positions Part II-A-2 as a separation of powers distinction rather than laissez faire economic assertion.
Part II-B: Textual Limits of IEEPA
Retaining the six vote majority in Part II-B, Roberts turns to IEEPA itself. Roberts agrees that IEEPA is an emergency authorization such that the president can “regulate…importation” during declared national emergency. While the government argues this language extends to the executive the power of tariff imposition, Roberts disagrees, reading the context of “regulate” and “importation” as necessarily distinct. Within its context in the stature, “regulate” emphasizes how the IEEPA has been used by previous administrations: freeze assets (e.g. Biden freezing Russian assets due to the invasion of Ukraine in 2022), restrict transactions (e.g. similarly, sanctions on Russian oil in 2022), and block property (President Carter invoked a $6 billion block on Iranian governmental property in response to the Iran Hostage Crisis in 1997).
Moreover, Roberts points out the notable fact that seemingly no other administration has ever imposed revenue-generating duties or tariffs under IEEPA stature dating back 50 years. Roberts implies that this is not incidental, but evidence that the intent to delegate tariff authority to the executive in IEEPA was never intended. Moreover, if Congress were to explicitly assign an Article I enumerated legislative right to the executive, it would necessarily be with overwhelming clarity.
As a result, Roberts rejects the government’s core argument surrounding its expanding powers, concluding “regulate” does not encompass taxation in any context due to an absent textual basis. In line with Roberts’ disposition, he centers the argument on the fact that the statute does not authorize these tariffs, demonstrating judicial restraint.
Part III: Reaffirming Legislative Primacy
Joined solely by the plurality due to the reaffirmation of the Major Questions Doctrine argument in part II, Roberts argues that IEEPA does not grant presidential tariff authority.
A broader implication of Learning Resources is that economic sovereignty, particularly taxation, remains a legislative function, rejecting an executive overreach to grant itself additional authority using emergency powers. As a result, a clear line is drawn between Constitutional and emergency actions. In just 20 pages, Roberts accomplished several judicial objectives: 1) reassert Congressional authority over taxation, 2) narrow the reach of the IEEPA, 3) expand the reach of the Major Questions Doctrine, even if not adopted by the majority, and 4) reinforce separation of powers and constitutionality during national emergencies.
Additionally, it signals Roberts’ continued goal to preserve the Supreme Court as an institution, grounding decisions in constitutional text and statutory interpretation rather than political vagaries and presenting rulings as neutral interpretations of constitutional boundaries. Given the ongoing national decline in the trust of the Supreme Court, reinforcing legitimacy cannot be unintentional. Moreover, Learning Resources could serve as a turning point in the Roberts Court Era regarding executive authority as a whole and particular emergency power applications. Regardless, Learning Resources demonstrates that despite the declaration of a national crisis, the Constitution's design for delegation of powers as a whole, particularly economic ones, takes precedence. Moreover, Roberts positions Learning Resources beyond the scope of tariff policy, reaffirming Congress’s preeminent authority over taxation and implicitly imposing a limit on executive power amid the Trump Administration’s flagrant, excessive assertions.