Learning Resources, Inc. v. Trump (2025): Testing the Limits of Presidential Power Over Trade
By Arjan Sodhi for
Lex Republica Legal Commentary Team
When the Supreme Court agreed to hear Learning Resources, Inc. v. Trump, docketed as No. 24-1287, it set up one of the most closely watched separation-of-powers battles of the 2025 term.
At stake is a deceptively simple question: Does the president have the authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs?
The answer could redefine how far executive economic power reaches — and how much discretion Congress has really ceded to the White House in the name of national security.
Whether the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. §§ 1701-1707, authorizes the president to impose tariffs on imports as part of an emergency response — or whether such actions exceed statutory limits and violate the Constitution’s allocation of trade and taxing powers to Congress.
Under the IEEPA, the president may “regulate, direct, and compel” certain economic transactions during a declared national emergency involving an “unusual and extraordinary threat” to the United States that originates “in whole or substantial part outside the United States.” The Act has traditionally been used to freeze foreign assets, restrict trade with hostile entities, and sanction individuals or governments — not to levy broad-based import duties.
Article I, Section 8 of the U.S. Constitution vests Congress with the power to “lay and collect Taxes, Duties, Imposts, and Excises.” Historically, Congress has delegated some trade authority to the president through statutes such as the Trade Expansion Act of 1962 (invoked in Trump v. International Trade Commission litigation) and the Trade Act of 1974, which permit tariffs under specific findings related to national security or trade imbalances.
The question here is whether IEEPA implicitly grants similar tariff authority — or whether the Trump administration stretched the statute beyond its intended national-security function.
In Learning Resources, Inc., a group of U.S. importers and small manufacturers challenged tariffs imposed by executive order under IEEPA. They argued that the Act allows the president to regulate or block transactions, not to tax goods entering the country. The distinction matters: regulation of trade is one thing, but creating a new revenue mechanism looks a lot like legislating.
The District Court for the District of Columbia sided with the administration, reasoning that the president’s national-security powers under IEEPA and Article II encompass temporary economic measures like tariffs if declared in response to a foreign “economic aggression” emergency.
The petitioners sought certiorari before judgment, and the Supreme Court for the following issue granted permission to consolidate the case with a related challenge (No. 25-250). In the following matter the arguments are scheduled for November 5, 2025. A Lot of legal scholar and commentator see if as a signal of how urgent and politically charged the Court considers this question.1
On one side we the Government perspective where they claim that the tariffs are a tool of economic defense akin to freezing assets or embargoing goods under IEEPA. On the other hand, critics see it as a power grab, arguing that tariffs are taxes in disguise and that only Congress can impose them under the Constitutional given powers.
This dispute sits squarely at the intersection of statutory interpretation and separation of powers. The Court must decide whether to read IEEPA broadly giving the executive a free hand in economic warfare — or narrowly, confining it to targeted financial restrictions.
The Justices’ questions may reveal deeper divisions:
Deeper divisions may be revealed by the Justices' questions:
Textualists might concentrate on whether the word "regulate" in the IEEPA text logically encompasses the word "impose tariffs."
The historical precedence of Congress in trade policy may be emphasized by institutionalists.
The Supreme Court’s ruling in Learning Resources, Inc. v. Trump could become a landmark in defining the modern boundaries of executive power in economic policy.
A decision upholding the tariffs would reinforce a broad view of presidential authority under emergency statutes effectively letting presidents weaponize trade policy as a form of unilateral foreign policy.
A decision striking them down would reaffirm Congress’s exclusive control over taxation and tariffs, reminding future administrations that “emergency” cannot be a standing license to legislate by decree.
Either way, the outcome will ripple far beyond trade law shaping how the balance of power between the branches operates in an era of global economic volatility.
Case Information
Case: Learning Resources, Inc. v. Trump, No. 24-1287
Lower Court: U.S. District Court for the District of Columbia
Argued: November 5, 2025 (scheduled)
Issue: Whether IEEPA authorizes the president to impose tariffs.
