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EMILY LEY PAPER, INC. v. TRUMP
3:25-cv-00464
N.D. Fla.
May 20, 2025
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Background

  • Plaintiffs challenged dramatically increased tariffs imposed on Chinese imports by a series of presidential executive orders, which relied on the International Emergency Economic Powers Act (IEEPA) and related statutes.
  • The President declared a national emergency related to drug trafficking and trade imbalances, then escalated tariffs on Chinese imports up to 145%.
  • Plaintiffs, whose businesses allegedly suffer financial harm from these tariffs, sued in federal district court seeking to invalidate the tariffs.
  • Defendants (U.S. government officials) moved to transfer the case to the U.S. Court of International Trade (CIT), arguing exclusive jurisdiction.
  • The central dispute: whether IEEPA authorizes tariffs such that the CIT, not the district court, must hear these challenges.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Does district court have jurisdiction, or CIT? District court has federal question jurisdiction under 28 U.S.C. §1331. CIT holds exclusive jurisdiction under 28 U.S.C. §1581. CIT has exclusive jurisdiction; transfer is appropriate.
Does IEEPA authorize the imposition of tariffs? IEEPA does not mention tariffs; "regulate" does not mean "impose tariffs." IEEPA's power to "regulate importation" includes tariffs. IEEPA provides authority to impose tariffs; CCPA precedent.
Major questions doctrine limits executive power? Imposing tariffs is a novel use of IEEPA, which fails the doctrine. Statute clearly authorizes President’s action here. Congress gave clear authorization; doctrine not implicated.
Are these tariffs for regulatory, not revenue, purposes? Tariffs primarily seek revenue. Aim is to address national emergencies, not revenue. Purpose is not revenue-raising; fits CIT's jurisdiction.

Key Cases Cited

  • K-Mart Corp. v. Cartier, Inc., 485 U.S. 176 (1988) (District courts are divested of jurisdiction under §1581 when CIT's exclusive jurisdiction applies)
  • Orleans Int’l, Inc. v. United States, 334 F.3d 1375 (Fed. Cir. 2003) (CIT jurisdiction removes specific trade actions from district courts)
  • United States v. Yoshida Int’l, Inc., 526 F.2d 560 (C.C.P.A. 1975) (Authority to regulate imports includes power to impose duties)
  • Regan v. Wald, 468 U.S. 222 (1984) (IEEPA’s powers are essentially the same as the Trading with the Enemy Act)
  • Christianson v. Colt Indus. Operating Corp., 486 U.S. 800 (1988) (Transferred court can revisit jurisdictional determinations)
  • Alimenta (USA), Inc. v. Lyng, 872 F.2d 382 (11th Cir. 1989) (Transfer orders under §1631 are not appealable)
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Case Details

Case Name: EMILY LEY PAPER, INC. v. TRUMP
Court Name: District Court, N.D. Florida
Date Published: May 20, 2025
Docket Number: 3:25-cv-00464
Court Abbreviation: N.D. Fla.