Sigvaris, Inc. v. United States
899 F.3d 1308
| Fed. Cir. | 2018Background
- Sigvaris imported graduated compression hosiery (15–20 mmHg) for men and women (various styles) and paid duties after Customs classified them under HTSUS 6115.10.40 (synthetic fiber hosiery).
- Sigvaris protested seeking duty-free treatment under HTSUS 9817.00.96 (articles specially designed for the use or benefit of physically handicapped persons). Customs denied the protest and Sigvaris sued in the Court of International Trade (CIT).
- The CIT granted summary judgment to the government, ruling the hosiery was not "specially designed" for physically handicapped persons and held only severe Chronic Venous Insufficiency (CVI) qualifies as a physical handicap.
- On appeal, the Federal Circuit affirmed the CIT’s outcome but rejected parts of its analysis: it held the correct inquiry focuses first on the persons for whose use the article is specially designed and then whether those persons are handicapped.
- The Federal Circuit concluded the hosiery is not "specially designed" for any specific class to a greater extent than for the general public — Sigvaris’s own advertising and expert testimony showed broad, non-exclusive uses (e.g., tired legs, pregnancy, long travel, fashion).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether inquiry should focus on the disorder (CVD) or on the persons for whose benefit the article is designed | Sigvaris: focus on the nature of the handicap the article addresses (CVD) | Government: must focus on whether the article is specially designed for persons who are actually handicapped | Court: focus on persons first — ask for whose use it is specially designed, then whether those persons are handicapped |
| Whether the hosiery is "specially designed" for physically handicapped persons under HTSUS 9817 | Sigvaris: hosiery alleviates CVD symptoms and thus is specially designed for those patients | Government: hosiery serves a broad population and any benefit to CVD sufferers is incidental | Court: not specially designed — intended use and marketing show general-purpose audience; 15–20 mmHg compression is only slightly above ordinary hosiery |
| Whether early-stage CVD qualifies as a physical handicap under HTSUS | Sigvaris: argues the condition addressed (CVD) supports classification | Government: only severe CVI interferes with major life activities and qualifies | Court: did not need to decide because hosiery fails the "specially designed" inquiry; also held severe CVI (not early-stage CVD) is the handicap that qualifies |
| Whether classification under HTSUS 6115 precludes duty-free treatment under HTSUS 9817 | Sigvaris: classification under 6115 governs | Government: 6115 describes the goods in entirety so no need to reach 9817 | Court: a good may be classifiable under 6115 yet still obtain duty-free status under 9817 if it meets 9817's conditions; here it does not |
Key Cases Cited
- United States v. Am. Home Assurance Co., 789 F.3d 1313 (Fed. Cir.) (standard of review for CIT summary judgment and statutory interpretation)
- Otter Prods., LLC v. United States, 834 F.3d 1369 (Fed. Cir.) (two-step tariff classification framework: define terms then apply to merchandise)
- Victoria’s Secret Direct, LLC v. United States, 769 F.3d 1102 (Fed. Cir.) (construing tariff terms)
- Wilton Indus., Inc. v. United States, 741 F.3d 1263 (Fed. Cir.) (structure of HTSUS headings and subheadings)
- Marubeni Am. Corp. v. United States, 35 F.3d 530 (Fed. Cir.) (definition of "designed")
- LeMans Corp. v. United States, 660 F.3d 1311 (Fed. Cir.) (citing HTSUS at time of importation)
- Schlumberger, 845 F.3d 1163 (Fed. Cir.) (interpretation of Additional U.S. Rules of Interpretation referenced)