Riddell, Inc. v. United States
754 F.3d 1375
Fed. Cir.2014Background
- Riddell imported football jerseys, pants, and girdles made of textiles (polyester/spandex); none included protective pads when imported, though each has pockets to accept pads worn during play.
- Customs classified the jerseys and pants under chapters 61/62 (apparel) and the girdles under heading 6212; Riddell protested, arguing classification under chapter 95 (sports equipment), subheading 9506.99.20 (football equipment), which is duty-free.
- The Court of International Trade granted summary judgment for the government, holding the items are "articles of apparel" under chapters 61 and 62, not sports equipment under chapter 95.
- Riddell appealed; the parties agreed the merchandise facts were undisputed, so classification turned on legal interpretation of HTSUS headings and GRIs.
- The appellate court affirmed classification of jerseys and pants as apparel, reversed the girdles’ classification under 6212 and held the girdles belong under subheading 6114.30.30 (other knitted garments).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether jerseys, pants, and girdles are "football equipment" under HTSUS 9506.99.20 | Riddell: items are football equipment or parts/accessories and thus duty-free | U.S.: items are textile garments classifiable under chapters 61/62, not chapter 95 | Court: Not sports equipment; apparel under chapters 61/62 |
| Whether apparel designed to accommodate protective pads converts to "sports equipment" | Riddell: specialized design for sport makes them equipment | U.S.: mere specialized apparel remains apparel absent transformative protective features | Court: Specialized use alone insufficient; need transformative protective material (Bauer exception) |
| Whether items can be "parts or accessories" to chapter 95 equipment | Riddell: pockets and intended use with pads make them accessories | U.S.: Note 1 excludes sports clothing (chapters 61/62) from chapter 95 parts rule | Court: Exclusion applies; apparel cannot be parts/accessories of chapter 95 goods |
| Proper apparel subheading for girdles | Riddell: girdles are knitted garments (6114.30.30) | U.S.: originally classified under 6212 but conceded girdles here lack body-support function | Court: Girdles classified under 6114.30.30 (reversing 6212 classification) |
Key Cases Cited
- Bauer Nike Hockey USA, Inc. v. United States, 393 F.3d 1246 (Fed. Cir.) (items containing substantial integrated padding held sports equipment)
- Lemans Corp. v. United States, 660 F.3d 1311 (Fed. Cir.) (apparel with limited padding can remain within apparel headings; sports equipment is mainly protective/non-apparel)
- CamelBak Prods., LLC v. United States, 649 F.3d 1361 (Fed. Cir.) (standard of review and classification principles under HTSUS)
- ABB, Inc. v. United States, 421 F.3d 1274 (Fed. Cir.) (items that perform separate function apart from other goods remain classifiable on their own)
- Wilton Indus., Inc. v. United States, 741 F.3d 1263 (Fed. Cir.) (application of GRIs and HTSUS structure)